Sanctions Screening

The AML screening service (pkg/aml) checks individuals and entities against global sanctions lists and politically exposed persons databases.

Sanctions Lists

List	Source	Coverage
OFAC SDN	US Treasury	Specially Designated Nationals
EU Consolidated	European Union	EU sanctions targets
UK HMT	HM Treasury	UK financial sanctions
UN Security Council	United Nations	Global sanctions
PEP Database	Multi-source	Politically exposed persons
Adverse Media	Multi-source	Negative news screening

Matching

The screening service uses three matching strategies:

Match Type	Method	Threshold
Exact	String equality	100%
Fuzzy	Levenshtein distance	Configurable similarity
Partial	Substring and token matching	Name component overlap

Risk Scoring

Each screening result receives a risk level:

Risk Level	Action Required
Low	Auto-approve, periodic rescreening
Medium	Manual review within 24 hours
High	Escalate to compliance officer
Critical	Block immediately, file SAR

PEP Detection

Politically exposed persons (current and former government officials, their family members, and close associates) trigger enhanced due diligence requirements:

Source of wealth verification
Source of funds documentation
Senior management approval for onboarding
Enhanced ongoing monitoring (quarterly review)

EDD Process

Enhanced Due Diligence is required for:

PEP matches
High-risk jurisdictions
Complex ownership structures
Unusual transaction patterns

Screening Hit ──► Risk Assessment ──► EDD Required?
                                          │
                      ┌───────────────────┤
                      ▼                   ▼
                  Standard CDD       Enhanced CDD
                  (periodic)         (source of funds,
                                      senior approval)