Financial Crime · Example

Sanctions disposition

Cadre name · Cerberus

Returns clear, block, or escalate after comparing the match and its identifiers.

Operating dossier

The job, permitted decisions, and owner

Mandate

Works sanctions name-match hits against supplied OFAC SDN evidence and records a clear, block, or escalate disposition.

Case arrives with: Case ID · Subject · Name · Payment · Amount · Context
Allowed outcomes: Clear · Block · Escalate
Where it fits: Alert to SAR · Agent Assurance

Operating logic

01Works OFAC name-screening hits by separating documented false positives from candidates that need a block or accountable escalation.
02Uses a conservative escalation rule because a missed true match can carry serious sanctions exposure; unresolved doubt is not treated as a clear.
03Clears a serious candidate only on a specific contradicting identifier (a birth date years apart, a different nationality, individual against entity); if it cannot name one, the case escalates.
04The illustrated design checks disclosed direct, indirect, and aggregated ownership against the OFAC 50 Percent Rule, retaining the calculation and source evidence for accountable review.
05Records every disposition with the closest candidate considered, how the identifiers compared, and a concrete next action. The record is what human review acts on.

Decision logic

01Works OFAC name-screening hits by separating documented false positives from candidates that need a block or accountable escalation.
02Uses a conservative escalation rule because a missed true match can carry serious sanctions exposure; unresolved doubt is not treated as a clear.
03Clears a serious candidate only on a specific contradicting identifier (a birth date years apart, a different nationality, individual against entity); if it cannot name one, the case escalates.
04The illustrated design checks disclosed direct, indirect, and aggregated ownership against the OFAC 50 Percent Rule, retaining the calculation and source evidence for accountable review.
05Records every disposition with the closest candidate considered, how the identifiers compared, and a concrete next action. The record is what human review acts on.

Must not: Invent missing evidence or act outside the permitted outcomes.
Human owner: Unresolved or policy-sensitive matches
Evidence retained: Structured outcome, observed path, and the source evidence used.

Case and record

One case, from supplied evidence to recorded decision

Supplied case

Representative case dataSynthetic or simulated data

Case ID: SCR-1001
Subject · Name: Aerocaribbean Airlines
Payment · Amount: $240,000
Context: wire payment
Subject · Type: entity
Subject · Country: Cuba
Payment · Direction: outbound
Payment · Counterparty bank: Banco Internacional

View the case data

Case key true-entity-cuba

{
  "caseId": "SCR-1001",
  "context": "wire_payment",
  "subject": {
    "name": "Aerocaribbean Airlines",
    "type": "entity",
    "country": "Cuba"
  },
  "payment": {
    "direction": "outbound",
    "amount": 240000,
    "currency": "USD",
    "counterpartyBank": "Banco Internacional"
  }
}

Recorded path and outcome

Cadre reference capture

A recorded path through an illustrative case.

Observed path

Screened the subject name
Reviewed the candidate sanctions record
Recorded the structured decision
Recorded the contracted disposition
Committed the contracted outcome

Recorded outcome

Block

Disposition

Open decision record

Evaluation and limits

Evaluation coverage and stopping points

Published evaluation map

Expected decisions, boundaries, and costly failure modes.

These cases show what the pack is asked to decide, when it should stop, and which plausible errors the evaluation is meant to expose. They are not a reliability score or independent validation.

Expected and borderline behavior

Routine judgments, close calls, and named stopping points.

Exact SDN entity name, sanctioned-country address
block.
Case key
true-entity-cuba
Matches via a listed alias
block/escalate.
Case key
alias-entity-cuba
Strong individual match with consistent DOB
block.
Case key
true-individual-consistent
Legitimate Trinidad carrier name-similar to a Cuba listing
clear on country/identity.
Case key
fp-entity-country
Common-name collision with a listed individual but DOB differs by decades
clear/escalate, must reason on DOB.
Case key
fp-individual-dob
Single-token name partially matches a listed individual, no other identifiers
escalate.
Case key
ambiguous-single-token
No OFAC match
clear.
Case key
clean-entity
Ordinary individual, no match
clear.
Case key
clean-individual

Boundary and misuse cases

Plausible inputs that could produce a costly or overconfident decision.

Entity-named operator of a listed Cuban vessel; must not clear on an entity-vs-vessel technicality.
Case key
adv-vessel-type-trap
OFAC 50% rule
subsidiary not listed but 60% owned by SDN parent KOMID (9345); name screen is clean, ownership disclosure is the trigger.
Case key
adv-ownership-50pct
Bare common name matching multiple distinct SDN persons, no secondary identifiers to disambiguate
escalate, not block-to-one and not clear.
Case key
adv-common-name-collision

Operating fit

Workflow placement and validation

Operating pattern

Decide, refer, or stop

Give the pack a short list of permitted decisions and require referral when the evidence cannot support one.

01Receive the case
02Gather named evidence
03Apply the decision rules
04Decide or refer
05Record the decision and owner

Wider workflows

Alert to SAR·Sanctions disposition Agent Assurance·Subject: sanctions decisions

Decision sequence and workflow placement

01Receive the case
02Gather named evidence
03Apply the decision rules
04Decide or refer
05Record the decision and owner

Wider workflows

Alert to SAR·Sanctions disposition Agent Assurance·Subject: sanctions decisions

Pattern guide

Institution-specific validation

These questions shape how the example fits an institution.

Policy and legal interpretation
Source coverage, quality, and freshness
Thresholds and exception calibration
Integration and degraded-mode behavior
Human approval and escalation design
Performance on the institution’s own case mix

Validation questions

Policy and legal interpretation
Source coverage, quality, and freshness
Thresholds and exception calibration
Integration and degraded-mode behavior
Human approval and escalation design
Performance on the institution’s own case mix

Inputs, actions, and outcomes

Give it

Case ID
Subject · Name
Payment · Amount
Context
Subject · Type
Subject · Country
Payment · Direction
Payment · Counterparty bank

It does

Screen namescreen_name
Get sdnget_sdn
Record dispositioncommitrecord_disposition

It returns · Disposition

Clear
Block
Escalate

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