Sanctions Screening Documenter

---
name: sanctions-screening-documenter
description: >-
  Document sanctions screening of customers, counterparties, beneficial owners,
  controllers, vessels, aircraft, addresses, and transactions against applicable
  official lists and restrictions. Use for onboarding, periodic or event-driven
  rescreening, alert disposition, ownership-and-control review, and audit evidence.
---

# Sanctions Screening Documenter

Create a reproducible screening record, not a certificate that a subject is "clear."
Determine applicable regimes and restrictions before interpreting a list result.

## Intake

Obtain the screening date and timezone, transaction or relationship, jurisdictions
and nexus, parties and roles, legal and trading names, aliases and scripts, dates and
places of birth or incorporation, nationalities, addresses, identifiers, ownership
and control, goods or services, routes, currencies, banks, vessels or aircraft,
screening tool and settings, prior alerts, licences, and escalation procedure.

## Screening and documentation method

1. Map sanctions jurisdiction from incorporation, nationality, location, conduct,
   persons, goods, technology, transport, currency, payment chain, and contractual
   commitments. Include UN measures only through the relevant domestic or regional
   implementation unless the decision-maker is directly bound otherwise.
2. Identify the current official lists, regime instruments, sectoral or activity-
   based restrictions, ownership and control rules, general licences, exceptions,
   reporting duties, and regulator guidance applicable at the screening time.
3. Preserve list provider, list names, official source, publication or retrieval
   timestamp, version or delta, dataset format, tool version, matching configuration,
   transliteration, thresholds, and any source outage or fallback.
4. Record the exact subject data screened and its provenance. Expand known aliases,
   former names, native scripts, identifiers, addresses, and connected parties; do
   not reduce screening to one Latin-script name.
5. Review every candidate using multiple identifiers, list program and measure,
   aliases, dates, locations, reference numbers, and narrative data. Treat a score
   as triage, not proof of match or non-match.
6. Analyse direct listing and current jurisdiction-specific ownership and control,
   including aggregation, indirect holdings, control rights, trusts, intermediaries,
   and entities acting for or on behalf of designated persons.
7. Assess transaction restrictions beyond asset freezes: sectoral finance, trade,
   services, investment, export, import, shipping, aviation, circumvention, and
   facilitation. Verify licence or exception scope, conditions, parties, dates, and use.
8. Classify the result as confirmed match, likely match, unresolved, false positive,
   no candidate returned, or other policy category. State evidence, counterevidence,
   reviewer, rationale, limitations, escalation, and approval.
9. Follow applicable hold, reject, freeze, block, report, licence, recordkeeping,
   confidentiality, and no-tipping-off procedures without taking irreversible action
   solely from an automated alert.
10. Set rescreening triggers for list changes, ownership or identity changes, new
    transaction facts, geographic exposure, licence expiry, and periodic review.

## Output

Provide the applicability map, subject-data sheet, source and configuration log,
candidate comparison table, ownership-and-control analysis, transaction restriction
review, disposition and approvals, action and reporting record, limitations, and
rescreening plan. Preserve enough detail for an independent reviewer to reproduce it.

## Guardrails

Do not call a fuzzy match conclusive, promise a false-negative-free result, use an
outdated list silently, or ignore non-list-based restrictions. Do not disclose a
potential match improperly or transact, freeze, reject, or report without the
required authorised review and current jurisdiction-specific legal advice.