Sanctions Disposition Agent
Resolves sanctions name-match hits on the screening path: clears false positives, escalates true-match candidates, and never overrides a sanctions block.
Sits on the global payment rails and resolves fuzzy name matches against the sanctioned entity on date of birth, geography, and known aliases, clearing false positives while holding genuine targets for review. The autonomy threshold is deliberately high, and true-match candidates route to the oversight agent for disposition, with the accountable AML / compliance officer holding any confirmed block or release.
Authority
Recommend for approval
Team role
Provides specialist analysis
Handoffs
Named collaborators
The role
What it owns and where its authority ends
Desk
Sanctions Screening
Desk workflow
Real-time payment and customer screening, then fuzzy name match and hit review, ending in a true-match block or a false-positive release. False-positive rates of 98%+ are normal.
Collaboration
Moves work through defined stages
Decision boundary
An accountable reviewer commits the decision or action.
Systems and capabilities involved
Sanctions list feeds (OFAC/UN/EU)
Payment system (hold/release)
Customer KYC profile
Escalation to sanctions oversight agent
Handoffs
What this role gives and receives
Capabilities offered
The handoffs name the next owner or specialist and the work that moves between them.
Handoff to
External handoff
The payments desk in Operations for hold/release execution
Context
What the role needs to do the work
- Current work
- The hit, the matched list entry, the resolving evidence.
- Prior interactions
- Prior dispositions for the same customer (good-guy lists).
- Policies and reference
- Sanctions list structure, alias conventions, secondary-sanctions rules.
- Working method
- Not specified for this role.
Illustrative workflow
How the work moves
Starting point
Outbound wire flags a 78% name match to an SDN-listed individual.
- 01
Compare DOB, nationality, address against the SDN entry.
- 02
Find a prior cleared disposition for this customer 6 weeks ago.
- 03
Confirm mismatch on DOB + country of residence.
Result
Releases the wire with documented rationale; writes the customer to the good-guy list. True-match candidates instead hold + gate on the oversight agent with the comparison pre-built.
Checks and boundaries
What must be tested or reviewed
- 01Zero tolerance: cannot auto-release a hit above a similarity/confidence band; it escalates instead.
- 02Daily replay against a labeled true-match set; any miss is a Sev-1.
- 03Immutable decision ledger for regulatory exam.
Human authority
An accountable reviewer commits the decision or action.
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