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 are screened against global sanctions datasets. Results carry a match strength, and each hit can be dispositioned by a member of your team.
Every disposition is attributed to the staff member who made it.
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.
If the adverse-media provider is unavailable, that dimension is 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.
- 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.