Sanctions Match Review: Record Evidence and Escalation

Preserve the exact alert context

Record the applicant or transaction reference, searched name and identifiers, screening timestamp, provider, source list and available list version or retrieval timestamp. Keep the original alert and the settings that produced it. Without this context, a later reviewer may be unable to explain why a result appeared or why a rescreen produced a different set.

Identify which regime and restrictions the list record represents, under the responsible policy owner's assessment. A sanctions dataset can contain different types of persons, entities and programs. Do not reduce every record to the same binary legal consequence or assume one list covers every obligation applicable to the operator.

Compare identity evidence, not just strings

OFAC's own match guidance directs users to compare the listing details with information about the relevant party and to follow their compliance procedures. Record corroborating and conflicting identifiers, source quality and gaps. A shared name or address can justify investigation without proving identity; a single discrepancy may also be insufficient to resolve an otherwise credible match.

OFAC explains that its search score measures name similarity and does not recommend one universal match threshold. Keep that technical score separate from the reviewer's conclusion. Do not tune a threshold merely to make a difficult alert disappear. If evidence remains incomplete, retain the case as unresolved and use the authorized escalation route.

Record the decision and any control effect

A case should show whether the potential identity match was confirmed, reasonably disqualified under the applicable procedure or left unresolved. Record the reasoning, evidence references, reviewer and required approval. Separately record the operational action taken and its authority. This worksheet does not prescribe a universal freeze, release or reporting rule.

Where a previous false-positive determination is reused, confirm that it covers the same identity, source record and current facts. Changed list information or new identifiers can invalidate the earlier conclusion. Protect the case evidence and limit communications to the approved process, including applicable confidentiality requirements.

Example: a similar name remains unresolved

A fictional applicant and a listed individual share a common name. The list provides a birth year, while the application provides only an unverified date. The analyst records the similarity and the evidence gap, requests the permitted verification and escalates under policy. The case is not cleared because the screen displayed a moderate score, nor confirmed solely because the names match.