Practical guide
What is sanctions case management? From alert to decision
Learn how sanctions case management connects possible matches, analyst evidence, comments, independent review, decisions, and later monitoring changes.
On this page
Turn an alert into a reviewable investigation
Sanctions case management organizes the work that follows a possible screening match. A case connects the submitted subject, source candidate, identifying evidence, analyst actions, and final reasoning. It should make clear which question remains open and who is responsible for answering it.
The original screening result is not the analyst’s conclusion. A system may return `potential_match`; the reviewer may later confirm or dismiss that candidate, or leave it unresolved while collecting evidence. Preserve both stages rather than overwriting the original outcome.
Give every candidate its own decision
A subject may match several records. One candidate can be dismissed while another remains open. The case needs to retain the authority, source, record ID, version, and matching explanation for each. A single case-level “cleared” label can conceal an unresolved second candidate.
Use OFAC’s match guidance as a source for OFAC identity-review questions. Other lists require their own interpretation. An export-control record is not automatically an OFAC blocking designation.
Keep facts, comments, and decisions distinguishable
Facts describe the customer and source record. Comments explain investigation work or questions. Decisions state a reasoned identity conclusion and its scope. The history should identify who added each item and when.
An external document reference should include enough provenance to find the right version in the approved repository. A comment saying “passport checked” is weaker than a controlled reference explaining what was compared and what that comparison established.
Define assignments and independent review
Assign cases to people with appropriate access and authority. When the organization requires a second review, that reviewer should be independent of the initial decision and should see the underlying reasoning. A handoff should specify the unresolved question, not merely notify a team that something is waiting.
SanctionsKit case review supports per-match decisions and policy-driven independent second review. It does not decide the applicable legal action on behalf of the business.
Reopen the comparison when relevant facts change
A dismissed candidate may need review after a new identifier, source correction, customer change, or policy change. Prior reasoning is useful history, not a permanent name-only exemption. Record why a reused decision remains applicable and when it must stop being reused.
Monitoring can bring later changes back to the team. A monitoring alert, a new screening, and a reopened case should retain their links so the reviewer can understand what changed.
Evaluate the quality of the finished record
Ask another authorized reviewer to reconstruct the case without talking to its author. They should identify the original result, compared facts, evidence sources, unresolved gaps, identity conclusion, approval, and separate business action.
Use the decision-note template and audit-trail guide to test whether the record supports that reconstruction.