Sanctions Screening Evidence

Why evidence matters

Regulators and auditors do not ask "Did you screen?" They ask "What was checked, which list version was active, and why did you clear this entity?" Verifex Evidence Capsule preserves all of this automatically — so your team can answer with structured data, not memory.

In OFAC enforcement actions, the ability to produce documented evidence of screening has been a key factor in penalty determination. Companies that can demonstrate systematic screening with timestamped records typically receive lower penalties than those with ad-hoc or undocumented processes. The Evidence Capsule is designed to provide exactly this documentation.

What regulators ask for during audits

Based on published examination manuals from OFAC, FinCEN, and the EBA, auditors typically request:

• A complete list of screening policies and procedures, including risk thresholds and escalation paths
• Timestamped records of every screening query, including the name screened, lists checked, and results returned
• Documentation of which sanctions list versions were active at the time of each screening
• Records of reviewer decisions (clear, review, escalate) with reviewer identity, timestamp, and rationale
• Evidence of periodic re-screening, including schedule, scope, and results
• Training records showing that compliance staff understand screening policies and procedures

Why list versions matter

Sanctions lists change daily. A name that was not on a list yesterday may be added today. If a regulator asks "Why did you clear this entity on March 15?" you need to prove that the entity was not on any relevant list as of March 15. Without version tracking, you cannot prove a negative.

The Evidence Capsule captures the exact list versions checked at screening time. If OFAC published an update at 2:00 PM and you screened at 1:30 PM, the capsule records that the screening used the pre-update version. This is critical for audit defense.

Evidence checklist

• Store request_id from every screening response in your case management system
• Capture evidence_capsule_id and evidence_capsule_url for audit retrieval
• Log the algorithm_version (e.g., v3.0.0) to reconstruct decision logic later
• Record list versions checked at the time of screening — they change over time
• Preserve the full match rationale including confidence score, match type, and source severity
• Document reviewer action (clear, review, escalate) with timestamp and user ID
• Export Evidence Capsules quarterly for external audit review
• Retain records per your plan limit: Free/Starter 30d, Growth 60d, Pro 90d, Enterprise 365d

Building your audit trail

An audit trail is more than a log file. It is a complete, tamper-evident record of every screening decision that your business makes. A robust audit trail includes:

• Query record: The exact name, type, and optional data (DOB, nationality) submitted for screening
• Response record: All matches found, confidence scores, match types, and source lists
• Decision record: The action taken (block, review, clear), who made it, when, and why
• List version record: Which sanctions list versions were active at screening time
• Algorithm version record: Which matching engine version produced the results

The Verifex Evidence Capsule captures all of this automatically in a single structured JSON document. You can retrieve it via API using the evidence_capsule_id returned with every screening response.

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