For teams with an incumbent screening tool and an evidence gap
Can you add an evidence layer to your existing screening provider?
Replacing a screening provider is expensive and risky, and often the incumbent's matching is fine, what is missing is the record. Many tools return alerts and a score, but not a reconstructable decision: which sources were current, whether coverage was complete, whether the candidate set was capped. This page is about evaluating an evidence layer that fills that gap on top of what you already run, and being honest about what such a layer can and cannot do.
Primary sources
- EBA/GL/2024/14, controls, data quality and record-keeping
The control and evidence expectations a screening operation must meet (applicable from 30 December 2025). An evidence layer exists to make these reconstructable regardless of which engine produced the alert.
- Screening Decision Record, the target record shape
The open reference for the fields an evidence layer should capture so that any screening decision can be reconstructed later.
What an evidence layer adds
- A coverage state per decision, which sources answered, which were stale, which were unavailable or excluded, instead of a bare alert.
- Candidate-set completeness and screening mode, so a capped or exact-only run cannot pass as a full screen.
- A retained, retrievable decision record with a content-integrity hash, keyed to your case or request ID.
- A recomputation check, validating the decision against the open reference so a false clear is caught rather than filed.
How to evaluate one
- 1Confirm it augments, not replaces: your incumbent keeps producing matches; the layer captures and structures the decision around them.
- 2Check what it can actually read from upstream, coverage, source list and versions, candidate completeness. It can only record what the incumbent exposes.
- 3Confirm it fails closed: if upstream signals a source was unavailable, the layer records partial coverage rather than a clean record.
- 4Check retrieval and integrity: can you fetch a record by ID for the full retention period, and prove it is unchanged?
- 5Test the boundary: feed it a case the incumbent screened with a stale list, and confirm the layer surfaces the staleness rather than hiding it.
Integration pattern
The clean pattern is a thin capture step in your screening workflow: when your incumbent returns a result, pass the result plus its source and coverage metadata to the evidence layer, which structures, validates and retains the decision record and returns a capsule reference you store on the case.
Nothing about the matching changes. What changes is that six months later you can produce the record, and show that a no-hit was, or was not, eligible to be treated as clear.
Limitations
- An evidence layer can only reconstruct what the upstream provider exposes. If the incumbent does not report source versions, coverage or candidate completeness, the layer cannot invent them, it will record that the information was not available.
- It does not improve the incumbent's recall or reduce its false positives; it makes the resulting decisions reconstructable. Matching quality remains a separate question.
- It is not a substitute for the screening itself, nor for your policy decision on whether to treat a result as clear.
- This page is an implementation reference, not legal advice.
Build the evidence, not just the alert
Questions
Do I have to replace my current screening tool?
No. An evidence layer is designed to sit on top of an incumbent, capturing and structuring the decision without changing how matches are produced.
What if my provider doesn't expose coverage or source versions?
Then the evidence layer records that those facts were not available, honestly, rather than fabricating them. It is also a strong signal that your incumbent's output is not fully reconstructable on its own.
How does Verifex do this?
Verifex can screen directly, or capture and validate a decision record around a result, sealing an Evidence Capsule with the coverage, completeness and integrity fields. Where upstream data is missing, the record says so.
This page is an implementation reference for engineering and compliance teams. It is not legal advice and does not certify any regulatory outcome. Regulatory obligations, their interpretation, and the decision to treat any result as clear remain yours. Verifex supports the workflow and preserves the evidence; it does not make the compliance decision.