Screening Policy
Who we screen, what we screen for, and what each result means.
1. When screening runs
Screening checks are created the moment an application is submitted for review, and every run is recorded in the audit log. Each subject on the application — the individual applicant or the signing officer, the business itself, and any ultimate beneficial owner — is screened separately across all three check types.
2. What we screen for
Sanctions
Every subject — the applicant, the business, and any ultimate beneficial owner — is checked against partner watchlists of sanctioned individuals and entities. This check runs before any application can be approved.
Politically exposed persons (PEP)
We check whether a subject holds, or has recently held, a prominent public function. A PEP match does not disqualify an applicant by itself — it raises the level of review the case receives.
Adverse media
Partner sources are searched for credible negative reporting connected to a subject, such as fraud or money-laundering allegations. Isolated or unreliable mentions are discounted by the compliance team during manual review.
We rely on partner watchlists and generic data sources; no list provider is named here, and raw list data never enters our systems — only the result of each check.
3. What each result means
No match was found on any partner watchlist. This is the expected outcome for the overwhelming majority of checks, and the case proceeds through review normally.
Something on a watchlist resembles the subject — most often a similar name. A potential match is escalated to the compliance team, who compare the identity details on the application against the list entry and resolve the check manually. Most potential matches turn out to be false positives.
The compliance team has confirmed the subject is the person or entity on the list. An application with a confirmed hit cannot be approved — the block is enforced by the system itself, not by reviewer discretion, and the attempted approval is refused and recorded.
Newly created checks start as Pending until they are run.
4. Escalation and record-keeping
Every screening run, escalation and resolution is written to the append-only audit log with the subject, check type and result. Reviewers can see the full screening picture on the case file before making a decision, and the applicant’s own record shows that screening took place without exposing watchlist details.