Practical guide
Sanctions investigation: compare evidence and decide what follows
Investigate a possible sanctions match using the original record, reliable identity facts, and a clear handoff for any unresolved decision.
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Confirm which identity and check you are investigating
A sanctions investigation begins with a specific candidate, not a general suspicion about a name. Open the retained case in Review queue in SanctionsKit. Check the submitted person or company, selected sources and current screening before gathering more facts.
Load the latest evidence if the case has changed. If the subject was wrong, use identity correction to create a linked replacement screening. A note cannot change what the original request contained. Keep that history clear so another reviewer can follow why the comparison changed.
Read the full source entry
Inspect the authority, list, record ID, source link, aliases and useful identity fields. Keep the source version used by the screening. If a newer official entry adds information, record it as new evidence rather than silently replacing the older facts.
A record repeated through an aggregated feed and an original list is not two independent sources proving the fact. Preserve where each entry came from. Different underlying lists can also impose different restrictions, so keep their identities visible through review.
Compare fields at the precision they provide
Read names, dates, countries, IDs and addresses in context. Keep approximate dates and alternatives visible. Check an ID's issuer before comparing it. A missing field is unknown; an older address may reflect a move rather than a different identity.
For a fictional company, two registration numbers may differ because they come from different registries or one is historical. Establishing that fact is a useful next step. Changing a name threshold repeatedly will not answer the registry question.
Add the fact that helps resolve the gap
Use Add match evidence beside the candidate. Record the useful identity fact, its source and why it can be compared. A company number with an unknown issuer remains uncertain until you know what registry supplied it. More text alone is not better evidence.
Use case notes or text attachments for wider context and approved external references for original files. Those links do not upload the originals. Collect only what the open identity or policy question needs, and keep it in the approved place.
Record the decision and complete the review steps
Choose Same person or entity, Different person or entity, or leave Unresolved identity with a reason. Record the separate business action and required outside checks. Submit only when the evidence and policy support it. Independent approval may still be needed.
The decision-note guide shows how to explain the reasoning. API clients can read investigation state. Permitted human reviewers must make decisions and give approval in the dashboard.
Assess restrictions and ownership separately
A confirmed identity does not answer every question about a proposed activity. Read the applicable measure and obtain the authorized decision. An unlisted company may also need ownership analysis under OFAC's 50 Percent Rule.
SanctionsKit does not build an ownership chart or decide whether a license or other authorization applies. Link those separate assessments to the case. Do not describe them as facts automatically established by the name check.
Escalate a question someone can answer
For a restrictions question, explain the proposed activity and relevant source measure. Include the evidence already reviewed and the exact decision needed. A screenshot of an alert cannot replace transaction context. Keep that legal or business assessment separate from the matching result.
- State whether identity is confirmed, different or unresolved, and cite the comparison.
- Describe the parties and their roles in the proposed relationship or transaction.
- Identify the authority, listing reference and restriction requiring interpretation.
- List unresolved ownership, geographic or authorization questions without assuming answers.
- Record the responsible decision-maker and preserve the response with its scope and date.
Sources and references
Authority and technical sources
SanctionsKit documentation
Frequently asked questions
What should I check before collecting more investigation evidence?
Confirm the submitted identity, selected coverage, current screening and exact candidate. A wrong subject or old case may be the issue. Start from the saved request and source record, not only the customer's current profile.
Do two feeds repeating the same listing provide independent proof?
Not necessarily. An aggregated feed may repeat the original authority's record. Preserve the source of each fact and avoid counting copies as separate confirmation. Read the actual underlying entry and restrictions.
Can I use a newer source entry to explain an older screening?
You can add it as new evidence, with its own date and source. Keep the earlier screening's source version intact. Otherwise the record can wrongly suggest that later facts were known when the original check ran.
What should a sanctions escalation ask the next reviewer to decide?
State the unresolved identity fact or the specific activity and restriction question. Link the evidence already gathered and identify the decision owner. A clear request avoids repeated work and prevents a match screenshot from being mistaken for a complete assessment.