Practical guide
Sanctions screening for MSBs: sender, recipient and review handoffs
Keep MSB transfer parties distinct, recover incomplete screening requests and connect retained results with reviewers and ongoing customer checks.
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Keep sender and recipient identities separate
Use SanctionsKit for the sender, recipient, business customer or agent selected by your MSB procedure. Give each party its own reference in the transfer system. A completed sender check does not establish a result for the recipient.
The responsible team can use FinCEN's MSB resources to assess broader duties. SanctionsKit supplies identity checks against selected sources and review. Identity verification, transaction-pattern monitoring and report filing need separate processes.
Run the check at the agreed transfer checkpoint
Open New screening and enter the legal party, correct type and known identifiers. Select the approved policy and Run screening. Create a saved profile with an External reference for a continuing customer; keep other parties' references separate.
An automated service can call POST /api/v1/screenings using the fintech example. Store one key and exact body per intended party check, then save data.id with the transfer. Test invented Sandbox inputs before authorized Production coverage.
Make the principal-agent handoff reviewable
Open a candidate in the Review queue and assign someone who can obtain the missing facts. A source record without a birth date leaves a gap, not a conflicting date. Record the identity finding and the business decision separately.
Share the authorized case reference and outstanding question between principal and agent. Check that the reviewer can access the evidence. Saying a check happened is not the retained result. Keep the transfer at its required state while review or approval is pending.
Recover a timeout without creating new work
A timeout may occur after acceptance. Retry the original operation with the same Idempotency-Key and unchanged body. Do not create a new key for every transport retry or turn a missing response into no_match. Follow the error contract for outages, rate limits and allowance caps.
A corrected recipient name changes the input. Use a new key for that new check. Preserve the earlier result and link both IDs to that recipient's transfer role. Recovering screening is separate from authorization to execute the transfer.
Reconcile continuing customers and portfolio checks
Create approved monitors in Monitoring, confirm the first check and assign later work. Scheduled and qualified source-triggered checks share the Production allowance with other screening. Inspect Usage & limits as the workload changes.
For periodic portfolios, use Bulk screening and reconcile every row to a result or failure. Keep retained evidence available to the principal's reviewers with access. Transaction-monitoring duties remain outside this identity-screening workflow.
Sources and references
Frequently asked questions
Does screening the sender cover the recipient of a transfer?
No. They are different legal parties. Run the checks your policy requires for each and save their separate result IDs with the transfer roles, even when both are linked to one transaction.
What should a principal receive from an agent's match review?
Share the authorized case reference, outstanding question and relevant retained evidence. Confirm the principal's reviewer can access it. A statement that screening happened does not explain which party, sources or findings it covered.
Should an MSB retry a timeout with a new screening key?
Reuse the original key and exact body for the same uncertain operation. A new key is for new screening work, such as corrected input. Keep the transfer decision separate while the result remains incomplete.
Does accepting a portfolio upload mean all MSB customers were checked?
No. Acceptance begins processing. Reconcile every row with its completed result or recorded failure, then handle required cases. Keep unfinished checks visible instead of using the upload status as portfolio completion.