Reviewing a sanctions match

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In short

A potential match says these two names are alike. Your job is to decide whether they are the same person or organisation, and to leave a reason that stands up when an auditor or regulator reads it later.

Read the match: the score, and why it scored that way.
Compare identifiers, not names: date of birth, nationality, documents, registration.
Fill the gaps from what you already hold, before asking anyone anything.
Decide: false positive, true match, or not enough yet.
Write the reason so a stranger could follow it.

The screens are described in Reviewing a potential match. This page is about the judgement.

The standard you are applying

Sanctions are different from suspicion-based reporting. You are not asking whether activity looks suspicious; you are asking a question of identity: is this the listed party?

Outcome	When
False positive	At least one strong identifier clearly differs, and nothing else ties them together
True match	Strong identifiers agree, and nothing contradicts them
Not enough yet	The names are alike and you can’t rule the match in or out with what you hold. Leave it open, comment on what is missing, and tell your MLRO

An open potential sanctions match already sends that party’s payments for review by default, so leaving a match open is not the same as ignoring it. See Real-time decisions: sanctions screening.

Step 1: read the match

Open the match and look at Score and matched fields first.

A name score near 1.00 with nothing else agreeing is common for frequent names. It tells you little by itself.
Look at what raised or lowered the score: Same date of birth, Same country and Same identity number are evidence for; Different date of birth, Different country and Different type (person or organisation) are evidence against.
Weak name match means only one part of the name agreed. Be more sceptical.

See How matching works.

Step 2: compare identifiers

Use Your record and the list entry. Work down from the strongest identifier.

Identifier	Strength	Notes
Identity or registration number	Strongest	The same passport, national ID or company registration number is close to conclusive. Lists often publish them
Full date of birth	Strong	A different full date of birth, verified against a document, rules a person out. Lists sometimes give only a year, or several dates
Nationality, place of birth	Medium	Helps, but people hold several nationalities and lists can be incomplete
Other names and aliases	Medium	Check the entry’s aliases against former names, trading names and transliterations you hold
Type	Strong against	A person can’t be a vessel. A company matching a person’s name is usually a false positive, unless the listed person owns or controls it: check
Address, occupation, remarks	Supporting	Read the publisher’s remarks; they often describe role, location and associates

The comparison shows the kind of identity document on your record, not its number. Open the customer’s profile to see the number, if your role allows it.

Step 3: fill the gaps

If you can’t decide, look further before you leave it:

The customer’s profile: onboarding documents, KYC tier, occupation, business registration.
For a company: directors, shareholders and signatories against the listed names.
For a counterparty: you usually hold only a name and perhaps a country and bank. Look at the payments it appears in and who your customer says it is.
The list’s own publication, for details the entry here doesn’t carry.

Step 4: decide

False positive. Select False positive. The pair is remembered and not raised again unless the list entry or the customer’s details change. Clearing a match against a sanctions list needs a second person by default; where your workspace has only one approver, only that person (by default the MLRO) can clear or confirm it, so assign the match to them with your comment. They are notified by email, text message or WhatsApp, as they chose; the message carries no name.

True match. Tell your MLRO before or as you select True match: your sanctions procedure starts now, and it has deadlines. Confirming needs a second person by default. Once it is applied, SpeculaPro:

flags the party (Sanctioned for a sanctions list);
opens a case, or adds to their open one;
blocks their payments in real-time decisions, by default.

What SpeculaPro does not do: freeze accounts or balances in your core system, stop payments your systems don’t ask it about, or report to any authority. Those are yours, under your procedure.

PEP matches are not prohibitions. A true PEP match means enhanced due diligence, senior approval of the relationship and closer monitoring, as your policy sets out. See PEP and high-risk customers.

Step 5: write the reason

The reason is kept with the match as evidence and is what the approver reads.

Weak	Strong
Not him.	Customer born 14 March 1996 (Ghana Card checked at onboarding). List entry gives 1988 and a different nationality. No other identifier agrees.
Same name, confirmed.	Same registered name and country as the listed company. Directors named in the listing are this account’s signatories (registry extract on file).

Say what you compared, where it came from, and what it showed. Don’t copy more personal data into the reason than the decision needs.

Common mistakes

Clearing on name alone. “Common name” is not a reason. Name a differing identifier.
Confirming on name alone. A perfect name score with no agreeing identifier is not a match.
Leaving matches open indefinitely. An open match holds the customer’s records from purge and erasure, and sends their payments for review.
Deciding your own. Where a second person is required, they must read your reason and check it, not wave it through.