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Automate sanctions screening before money moves

A screening agent checks each new counterparty and its directors in ComplyAdvantage, applies your match rules, and holds the payment for a reviewer whenever there is a possible match.

Book a demoSee how it runs

Works with

  • Payments system · via Custom REST

and any system with an API via Custom REST

What is sanctions screening?

  • The procedure

    Sanctions screening checks a counterparty, its directors and its owners against the lists your policy names before money moves. Many possible matches are common names, so the work is comparing identifiers such as date of birth and country. A match that cannot be ruled out keeps the payment on hold and goes up the chain.

  • What the agent does

    • Screens the counterparty, directors and owners in ComplyAdvantage

    • Puts the match details next to the counterparty record for the reviewer

    • Releases the payment hold through Custom REST once screening is clear

    • Re-screens your counterparty list on the schedule you set

  • What your team decides

    • Whether each possible match is a false positive

    • When a payment held on a match is released

    • Escalations to your MLRO or compliance officer

    • Next steps on a confirmed match, under your policy

Example runs for sanctions analysts, payments operations, MLROs or compliance officers

Sample data

Sanctions Screening Agent

Screens each new counterparty before the first payment goes out.

  • ComplyAdvantage
  • +1

Trigger: Inbound webhook · new counterparty

From a procedure Sanctions screening · v2.0

Priya

Screen the new counterparty Corvid Freight before the first payment.

Sanctions Screening Agent

  1. Screened Corvid Freight and its 2 directors in ComplyAdvantage
  2. No possible matches on the company or the directors screening.hits == 0
  3. Recorded the result against the counterparty
  4. Released the payment hold in the payments system through Custom REST

Cleared. No matches. The screening result and the procedure version are stored with the counterparty record.

4 steps · 0 reviews

Sanctions Screening Agent

Screens each new counterparty before the first payment goes out.

  • ComplyAdvantage
  • +1

Trigger: Inbound webhook · new counterparty

From a procedure Sanctions screening · v2.0

Tom

Screen the new counterparty Ostrava Metals before the first payment.

Sanctions Screening Agent

  1. Screened Ostrava Metals and its directors in ComplyAdvantage
  2. Found 1 possible match on a director's name
  3. Asked a reviewer, because any sanctions hit needs a person Waiting for a reviewerLena: false positive, date of birth differs
  4. Recorded the decision and released the payment hold

Cleared after review. One possible match, ruled a false positive by Lena. The match details, her reason and the procedure version are in the audit log.

4 steps · 1 review

Sanctions Screening Agent

Screens each new counterparty before the first payment goes out.

  • ComplyAdvantage
  • +1

Trigger: Inbound webhook · new counterparty

From a procedure Sanctions screening · v2.0

Marcus

Screen the new counterparty Harbor Lane before the first payment.

Sanctions Screening Agent

  1. Screened Harbor Lane and its owners in ComplyAdvantage
  2. Found 1 possible match on an owner, with strong identifier overlap
  3. Held the payment and paused for a reviewer on the owner match Waiting for a reviewerPriya: match stands, escalate to your MLRO or compliance officer
  4. Kept the payment hold and recorded the escalation

Escalated. Priya could not rule the match out. The payment stays on hold while your compliance officer reviews the evidence.

4 steps · 1 review

Setting up the Sanctions Screening Agent

Connect your systems

Screen in ComplyAdvantage, save evidence to Google Drive, and place or release holds in your payments system through Custom REST.

  • ComplyAdvantage
  • Google Drive
  • Sumsub
  • Payments system · via Custom REST

Write the rules

Any possible match goes to a person. The rule that decides it is plain CEL you can read, test and version.

Sample data
screening.hits > 0Ask a reviewer
screening.hits == 0Release hold
review.decision == "match_stands"Escalate

Add reviewers where the procedure says

A named reviewer sees the match details next to the counterparty record, and the payment hold stays until they decide.

Sample data

Review requested: Ostrava Metals

Reason
Possible sanctions match on a director
Rule
screening.hits > 0
Procedure
Sanctions screening · v2.0

False positiveEscalate

Start it from the event

Screen a counterparty as soon as your payments system posts it to a webhook, again when its details change, and on a nightly schedule across the whole counterparty list.

  • Inbound webhook · new counterparty
  • Daily at 02:00 · re-screen the counterparty list
  • Inbound webhook · counterparty details changed

Version and evaluate

Keep scenarios for a clean counterparty, a false positive on a common name and a match that stands. Each sanctions screening version must pass them before it can be published.

Sample data

Sanctions screening · v2.0Published

12/12 scenarios passed

Sanctions screening · v1.2 Superseded

Sanctions screening · v1.1 Superseded

Share with the team

Sanctions analysts review possible matches, payments operations can read why a payment is held, and auditors see each screen with the version it used. An Author owns the match rules.

  • Admin
  • Author
  • Reviewer
  • Auditor

Questions about sanctions screening automation

Does the agent ever clear a possible match?

No. Each possible match goes to a named reviewer, and the payment hold stays until they decide. The agent releases a hold only when screening returns no matches or a reviewer rules the match out.

Which lists does it screen against?

The lists set up in your ComplyAdvantage account. Verkflo runs the screen in ComplyAdvantage and applies your match rules to the results.

Can it re-screen existing counterparties?

Yes. A schedule can re-screen the counterparty list each night, and a webhook can start a screen when a counterparty's details change.

What does the reviewer see?

The match details, the counterparty record and the rule that paused the run. Their decision and reason are written to the audit log.

Controls your auditors will ask about

These controls apply to each agent you build. Sample data

Related use cases

See all use cases

Run this procedure as an agent

Book a demo with your own version of this procedure, and we'll show it running with each step logged.

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