Scenario: Agent Refunds a Sanctioned Party

The refund scenario - every outbound payment needs the screen.

The setup

Your agent refunds a customer for a returned product. The customer's wallet was clean at purchase - but is now on the sanctions list.

The gap

• Refunds are treated as routine, unscreened
• A refund is a payment - returning funds to a blocked party is prohibited
• The designation happened after the original purchase; the refund is new exposure

The control

1. Screen every refund destination before processing
2. Re-screen counterparties on a schedule (designations land between releases)
3. Blocked refunds are held, not silently returned
4. Every result logged with the list version

The takeaway

Refunds are a payment path - the screen runs on every outbound payment, including returns and reimbursements.