Screening

Every person and entity connected to an application is screened, and a screening result that would block approval cannot be quietly inherited or ignored. Clearing one is an explicit, attributed act.

Sanctions and watchlists

Individuals and entities connected to the application, screened against global sanctions datasets.

Adverse media

Automated media screening with per-source relevance annotation.

Re-screening

Refreshes on a schedule and when a subject’s identifying details change.

Screening exceptions

An attributed MLRO sign-off where the compliance judgement is to proceed.

Sanctions and watchlists

Individuals and entities connected to the application are screened against global sanctions datasets. Results carry a match strength, and each hit can be dispositioned by a member of your team.

Disposition	Meaning
Confirmed	The hit is a genuine match for this subject.
False positive	The record matched on name or detail but is not this subject.
Marked reviewed	The hit has been examined and recorded as considered.

Every disposition is attributed to the staff member who made it.

A critical hit blocks approval until it is dispositioned

The disposition must also be newer than the most recent screen. Re-screening a subject therefore reopens the gate rather than inheriting a stale clearance.

Adverse media

Automated media screening runs alongside sanctions, with per-source relevance annotation so an analyst can mark which findings actually pertain to the subject. Findings can be grouped into cases for review across parties, and a subject can be re-screened on demand.

Adverse media is load-bearing for the decision. A screen that failed, could not run because the provider is unavailable, is still pending, or was never run blocks approval. A pending or never-run screen is released by the screen completing; an attributed MLRO exception can be recorded only against a screen that failed or could not run. In the rating, that dimension is meanwhile excluded and flagged "not assessed" rather than counted as clean. See Risk rating for the full set of fail-closed guarantees.

Re-screening

Screening refreshes on a schedule and when a subject's identifying details change, so a case that sat in review for weeks is not decided on stale data. The dashboard warns when results are stale.

Screening exceptions

Where a result would block approval but the compliance judgement is to proceed, an MLRO can record an attributed exception. The exception is part of the audit record, not a way to make the finding disappear.

Only the MLRO role can record one. See Roles and access.

How screening reaches the decision

Screening must be complete with no failed or pending screens before an application can be approved.
Every critical sanctions hit must be dispositioned, after the most recent screen.
An adverse-media screen that failed, could not run, is pending or was never run blocks approval. A pending or never-run screen is released by completing; an MLRO exception can be recorded only against one that failed or could not run.
A screening call that errors is recorded as failed, never read as a clean pass.

These are part of the completeness gate described in Onboarding lifecycle.