Reviewing a potential match

In short

A potential match is a question: is this customer, or this counterparty, the person or organisation on the list? Somebody has to answer it. You do that on the Screening page:

• False positive: it is someone else with a similar name. SpeculaPro remembers your answer, so the same pair isn’t raised again.
• True match: it is the listed party. SpeculaPro flags them with a risk designation and opens a case, or adds to their open case.

Most potential matches are false positives. The job is to tell the two apart quickly, and to leave a reason somebody else can follow a year later.

This is not legal advice; confirm with counsel

What you must do on a true sanctions match (freezing, reporting to the authority, and how fast) is set by your law and your regulator, not by SpeculaPro. SpeculaPro records your decision, flags the party and opens a case; it does not freeze an account or file anything with an authority for you. Confirm your procedure with your legal adviser.

Before you start

To	You need
See the Screening page and read a match	screening.view
Assign, comment on and resolve a match	screening.review as well
Confirm or clear a match against a sanctions list while a second person’s approval is not in effect	screening.approve as well
Approve a decision somebody else made	screening.approve
See the customer’s date of birth in the comparison	entities.view_pii

By default, analysts, senior analysts, L2 investigators and the MLRO can review. The MLRO approves. Auditors and administrators can read matches but not decide them.

In a default workspace, only the MLRO decides sanctions matches

A decision on a match against a sanctions list is never one reviewer’s alone. Either a second person approves it, or, while that approval is not in effect, only someone with screening.approve can take it. Approval starts applying once two active people hold screening.approve, and by default only the MLRO role does. So until you give the permission to a second person, the MLRO decides every sanctions match, and other reviewers can assign and comment only. See When a second person has to approve.

The queue

Select Screening in the side menu. The page is headed Potential matches and shows the Review queue, newest first.

On each row	Meaning
Score	The match score, from 0 to 1.00. Higher means closer
Name	The customer or counterparty as it was screened, labelled Customer or Counterparty
Entry on list	The list entry it matched and the list or provider it came from
Kind	Sanctions, PEP, PEP relative or associate, Adverse media or Watch list
Waiting for approval	Someone has decided, and the decision waits for a second person
Status	Open, True match, False positive, No longer matches or Delisted
Person	Who it is assigned to, or Unassigned
Age	How long ago it was raised

Use the tabs to choose a status: Open (the default), True matches, False positives or All. Then narrow the list with the four filters:

Filter	Choices
List or provider	Any list, or one list or provider your workspace has matches on
Kind of list	Any kind, or one of the five kinds above
Who matched	Customers and counterparties, or only one of them
Assigned to	Anyone, Assigned to me, Unassigned, or a named reviewer

The page shows up to 200 matches. When there are more it says First 200 matches: narrow the filters to see the rest.

When nothing is open the page says Nothing to review. New potential matches appear as people are onboarded and as lists change.

Reading a match

Select a row to open the match. The page has three parts.

Side by side

Your record and the list entry puts what you hold next to what the list says:

Detail	Your record	The list entry
Name	The name on record now	The entry’s main name
Other names		Aliases and other spellings
Type	Person, organisation, vessel or aircraft	The same
Date of birth	The customer’s date of birth, if you may see personal data	Every date of birth the list gives
Nationality and country	Nationality and country of residence (customers) or the counterparty’s country	Nationalities
Identity documents	The kind of document on record. The number is never shown here	The documents and numbers the list publishes
Programmes		The sanctions programmes the entry falls under
Listed on		When the entry was listed

Any remarks the publisher wrote appear underneath. Open the customer takes you to the customer’s profile, if you may see customers.

Two notes can appear:

• The record this match is about is no longer on file: only the name as it was screened is shown.
• The list entry is no longer in the current version of the list.

Why it matched

Score and matched fields shows the match score, the name score alone and the threshold in force when the match was found, then which name was compared with which, and each thing that raised or lowered the score: Same date of birth, Different country, Same identity number, Weak name match and so on. See How matching works.

Timeline

Every comment, assignment and the decision, newest first, with who and when. It is the match’s own audit trail and can’t be edited.

How to take or assign a match

1. Open the match.
2. Select Assign to me to take it, or choose a colleague under Assign to…. Only people who can review matches are offered.
3. To give it back, select Unassign.

Only an open match can be assigned. Assigning is optional: you can resolve a match that is nobody’s, or somebody else’s.

Nobody is notified

When you assign a match to a colleague, they get a notification through the channels they chose under Settings → Notifications (email, text message or WhatsApp), in their language: A potential screening match is assigned to you. It names you and links to the match. It carries no name, no list and no score, because those messages leave your institution’s control. Taking a match yourself notifies nobody, and so does unassigning. Each assignment sends one message, so giving the same match back to the same person later tells them again. There is no inbox in the app: see Notifications.

How to comment

1. Open the match.
2. Under Timeline, type in Comment: what you checked, and what is still missing.
3. Select Add comment.

A comment has up to 4,000 characters. You can comment on a match in any status, including one already decided.

Comments are about a real person

Write what a colleague needs to follow your reasoning, and nothing more. Comments and decision reasons are personal data: when the customer is later erased or pseudonymised, their text is replaced with Removed (data protection).

How to clear a false positive

Clear a match when you are satisfied the two are different people or organisations.

1. Open the match and compare the two sides: date of birth, nationality, documents, and for a company its registration and directors.
2. Select False positive.
3. Under Reason, say what rules it out, for example Customer born 1996 (Ghana Card checked at onboarding); the list entry gives 1988. The reason is 3 to 2,000 characters.
4. Select Clear as false positive.

What happens:

• The match becomes False positive, with your name and reason.
• The pair goes on the good-guy list: this customer and this list entry are not raised again. The clearance stops counting, and the pair can be raised again, when the list entry changes or the customer’s screened details change (name, date of birth, country, identity document).
• If the customer’s records were being held only because of this match, the hold ends. See What is kept.

How to confirm a true match

Confirm a match when you are satisfied it is the listed party.

1. Open the match and compare the two sides.
2. Select True match.
3. Under Reason, say what makes it the same party: the documents and identifiers you compared.
4. Select Confirm true match.

What happens, all together or not at all:

• The match becomes True match, with your name and reason.

• The customer or counterparty gets a risk designation matching the kind of list:

  The match’s kind	Designation set
  Sanctions	Sanctioned
  PEP	PEP
  PEP relative or associate	PEP relative or associate
  Adverse media	Adverse media
  Watch list	Watchlist

  If they already hold that designation, it is kept and no second one is added. A match with several kinds sets only the gravest, in the order above.

• An alert is raised and moved into a case: the party’s active case of the same kind if there is one, otherwise a new case assigned to the reviewer who decided. A sanctions match makes a sanctions case with critical severity; any other kind makes an AML case with high severity. The match page links to the case.

• From then on the designation rules apply to them, and real-time decisions follow your workspace’s screening policy: by default, a payment to or from a confirmed sanctions match is blocked.

A confirmed match is not raised again while its designation stands. If someone later removes the flag, the question is open again: the next screening can raise a new potential match, and the confirmed match stops counting in real-time decisions.

If the customer or counterparty no longer exists, confirming is refused: the customer this match is about no longer exists.

When a second person has to approve

Some decisions are too serious for one person. Under your workspace’s approval policy:

Decision	Approval type	Default
Confirming any match as a true match	Sanctions matches and true matches	On
Clearing a match against a sanctions list	Sanctions matches and true matches	On
Clearing a PEP, adverse-media or watch-list match	PEP and adverse-media false positives	Off: one reviewer’s reasoned decision is enough

A policy that is on starts applying once at least two active people hold screening.approve. Until then, or when your workspace has switched the policy off, approval is not in effect, and who may decide depends on the kind of match:

The match	While approval is not in effect
Against a sanctions list (confirming or clearing)	Only someone with screening.approve can decide it, and their decision applies at once. A reviewer without it sees no False positive or True match button, and this note instead: Only someone with the screening.approve permission (by default the MLRO) can confirm or clear a match against a sanctions list in this workspace: approval by a second person is not in effect here, so it is not a decision a reviewer takes alone. You can still assign the match and comment on it.
PEP, adverse media or watch list	Any reviewer decides it alone, and the decision applies at once

The dialog always says which of the three applies to the decision you are about to take:

• This decision needs a second person in this workspace. The match stays open until someone else with screening.approve approves your decision, and your reason is what they read.
• Your decision applies at once. Approval by a second person is not in effect for sanctions matches in this workspace, so only people with screening.approve, like you, can decide this match.
• Your decision applies at once: this kind of decision does not need a second person in this workspace.

When approval applies:

1. You decide as above. The reason you type is what the approver reads; you are not asked for a second one.
2. The match stays open and shows A decision on this match is waiting for a second person. In the queue it carries Waiting for approval.
3. Someone else with screening.approve opens Approvals, reads your reason and approves or rejects. You can’t approve your own decision.
4. On approval the decision is applied exactly as described above. On rejection the match stays open for another decision.

While a decision waits:

• the customer’s records stay held, because the match is still open;
• real-time decisions still treat it as an open potential match (by default: review);
• if a re-screen changes the match’s score or the list entry changes, or the match closes by itself, the request is closed as out of date and you decide again on what is there now.

Where the approver is recorded

The match’s timeline and its Confirmed by or Cleared by line name the reviewer who decided. The person who approved is recorded on the change request and in the audit log, not on the match.

Matches that close by themselves

You don’t have to decide every match. SpeculaPro closes an open match when it stops being true:

Shown as	Why
No longer matches	A later screening no longer found it: the customer’s details, the list entry or your threshold changed
Delisted	The entry was removed from its list
No longer matches, closed: list no longer screened	Your workspace stopped screening against the list

These appear under All. See Why a match was closed.

What is recorded

Each action is on the match’s timeline and in the audit log: screening.hit.assign, screening.hit.comment (the length of the comment, not its text), screening.hit.clear and screening.hit.confirm (the list, the entry, the kinds, your reason and what was created). A cleared match also writes screening.good_guy; a confirmed match also writes the designation’s, the alert’s and the case’s own entries.

Your reason is copied into the audit log, and for a true match into the designation’s reason. Erasing the customer later blanks it on the match’s timeline but not in the audit log, which is never edited. Keep reasons factual and short.

Limits

• No notification when a new match arrives, only when a colleague assigns one to you. Watch the Open queue, or Unassigned.
• The approver isn’t shown on the match, only on the change request and in the audit log.
• A match with several kinds sets one designation, the gravest. Add the others by hand if your policy needs them: see Flagging a customer.
• A decision can’t be undone on the match. To reverse a false positive, wait for the pair to be raised again or screen the customer on demand after their details change. To reverse a true match, revoke the designation and close the case.
• Only sanctions matches affect real-time decisions. A PEP or adverse-media match changes a decision only through the designation a confirmed match sets and the rules that read it.

Related

• Potential matches
• How matching works
• Playbook: reviewing a sanctions match
• Approvals
• Risk designations
• Screening API