---
name: sanctions-screening-decision-writer
description: >
  Document sanctions screening decisions with evidence, analysis, and rationale
  to an auditable standard. Use this skill when a user mentions sanctions screening,
  sanctions decision, OFAC, SDN list, EU consolidated list, UK sanctions, UN
  sanctions, PEP screening, adverse media, sanctions compliance documentation,
  true match, false positive, potential match, or screening alerts. Also trigger
  when users need to document why a screening alert was cleared or escalated, or
  when preparing sanctions compliance records for regulatory examination.
  This is NOT a screening tool — it documents the decision AFTER screening.
---

# Sanctions Screening Decision Writer

Document sanctions screening decisions to an auditable, legally defensible
standard. Following the evidentiary benchmark established in *Tonzip Maritime
SA v 2Rivers MMTC Ltd* (English Commercial Court, 2024), screening decisions
must be "documented, evidence-based, contextual analysis" rather than cursory
checks or blanket suspicion.

## When to Use

- You have run a sanctions screening and need to document the decision
- You need to clear a potential match (false positive) with proper documentation
- You need to escalate a true or possible match with supporting evidence
- You are preparing screening records for audit or regulatory examination
- You are building templates for your compliance team's screening workflow

## Core Principle

**A screening decision without documentation is no decision at all.** Regulators
and courts expect to see what was checked, what was found, what analysis was
performed, and what conclusion was reached. The *Tonzip* judgment reinforced
that contractual sanctions clauses require reasonable, evidence-based assessment
— not reflexive blocking based on nationality or geography alone.

## Input Requirements

Ask the user to provide:

1. **The screened party** — name, date of birth (if individual), jurisdiction of incorporation (if entity), address, nationality/citizenship
2. **The screening context** — what triggered the screening (new customer onboarding, transaction screening, periodic review, vessel screening)
3. **The screening results** — which lists were checked, any alerts generated, match scores
4. **Available identification documents** — passport, company registration, LEI, IMO number
5. **The transaction details** (if applicable) — amount, currency, counterparties, goods, route

## Decision Documentation Framework

### Section 1: Screening Parameters

```
Screening Reference: [unique ID]
Date of Screening: [date]
Screened Party: [full name as screened]
Party Type: [Individual / Entity / Vessel]
Screening Trigger: [Onboarding / Transaction / Periodic Review / Event-Driven]
Screened By: [analyst name/ID]
```

### Section 2: Lists and Databases Checked

Document every source checked:

| Source | Version/Date | Result |
|--------|-------------|--------|
| OFAC SDN List | [date] | [No match / Alert — match score] |
| OFAC Non-SDN Lists (SSI, FSE, NS-MBS) | [date] | [No match / Alert] |
| EU Consolidated Sanctions List | [date] | [No match / Alert] |
| UK OFSI Consolidated List | [date] | [No match / Alert] |
| UN Security Council Consolidated List | [date] | [No match / Alert] |
| National lists (specify) | [date] | [No match / Alert] |
| PEP databases | [source, date] | [No match / Alert] |
| Adverse media | [source, date] | [No findings / Findings — summarize] |
| Vessel registries (if applicable) | [source, date] | [details] |
| Shipping databases / AIS (if applicable) | [source, date] | [details] |

### Section 3: Alert Analysis (if alerts generated)

For each alert, document:

**Alert [number]:**
- **Listed party:** [name as it appears on the sanctions list]
- **List:** [which sanctions list]
- **Listing reason:** [why the listed party is designated]
- **Match score:** [if automated screening tool provides a score]
- **Comparison of identifiers:**

| Identifier | Screened Party | Listed Party | Match? |
|-----------|---------------|-------------|--------|
| Full name | [name] | [name] | [Exact/Partial/No] |
| Date of birth | [DOB] | [DOB] | [Match/Mismatch/N/A] |
| Nationality | [nationality] | [nationality] | [Match/Mismatch/N/A] |
| Address | [address] | [address] | [Match/Mismatch/N/A] |
| ID document | [number] | [number] | [Match/Mismatch/N/A] |
| Photograph | [available?] | [available?] | [Compared/Not available] |

- **Contextual analysis:** [Detailed reasoning for why this is a true match,
  possible match, or false positive. Reference specific evidence.]

### Section 4: Decision

```
Decision: [CLEARED — False Positive / ESCALATED — Possible Match / BLOCKED — True Match]
Rationale: [Summary of the evidence and reasoning supporting the decision]
Approved By: [senior compliance officer name/ID]
Approval Date: [date]
Next Review Date: [if periodic monitoring applies]
```

### Section 5: Record Retention

Note the retention requirements:
- Screening records must be retained for [5/7/10] years per [applicable regulation]
- All supporting documentation (screenshots, list extracts, ID copies) must be
  archived with this decision record

## Output Format

```markdown
# Sanctions Screening Decision Record

**Reference:** [ID]
**Date:** [date]
**Classification:** [CLEARED / ESCALATED / BLOCKED]

## Screened Party
[Name, identifiers, context]

## Screening Summary
[Which lists checked, dates, results]

## Alert Analysis
[For each alert: listed party, comparison table, contextual analysis]

## Decision and Rationale
[Clear statement of decision with evidence-based reasoning]

## Approval
- **Analyst:** [name]
- **Approver:** [name]
- **Date:** [date]

## Retention
[Applicable retention period and regulation]
```

## Important Notes

- This skill documents decisions. It does not perform sanctions screening itself.
- Sanctions lists change frequently. Always screen against the most current version.
- False positive documentation is as important as true match documentation. Regulators
  want to see that false positives were properly analysed, not rubber-stamped.
- For automated adversarial sanctions screening — cross-referencing party data
  against sanctions lists, vessel registries, AIS data, and beneficial ownership
  chains — see [DiligenceWorks](https://diligenceworks.online).