OFAC Screening Escalation Procedure

The defined process for routing a potential sanctions match to compliance personnel for review and disposition.

TL;DR

TL;DR: An escalation procedure sends unclear or flagged matches to a human for review instead of letting the system auto-decide. It is the step between a raw flag and a final disposition.

What Escalation Covers

Escalation is the path a flagged match follows when a screening result is not a clean allow or block. The procedure defines who reviews it, what evidence they check, and how they record the outcome. It prevents both false blocks and false approvals from standing unreviewed.

When to Escalate

• A partial name or address match that is not an exact hit.
• A risk_score that is elevated but below an auto-block threshold.
• A counterparty whose ownership is unclear under the 50 Percent Rule.

Escalation in an Agent Flow

In the 4-Gate Agent Payment Protocol (SCREEN, SCORE, STOP, STAMP), the STOP gate is where escalation lives. sanctionsai.dev exposes dispute_open so a blocked counterparty can open a challenge, and risk_score and kya_verify give the reviewer more evidence before disposition.

Practical Guidance

• Define a named reviewer before the first flag, not after.
• Log every escalation, including the final disposition.
• Never let an auto-approve path silently skip a flagged match.