Screening Evidence Standard
A screening control is only useful if the result can be reconstructed, reviewed and challenged later.
The standard applies to negative results as well as hits. A clean search still has to show what was searched, where, when, with which identifiers and under which parameters.
1. Required evidence fields
| Field | Purpose |
|---|---|
| Subject and subject type | Customer, UBO, director, authorised person, bank, counterparty, employee, vendor, goods or service. |
| Identifiers used | Name, aliases, DOB, nationality, registration number, SWIFT, address, website, goods code or other relevant identifier. |
| Source class and source used | Commercial screening, official sanctions list, registry, adverse media, public search, domain intelligence or trade-control source. |
| Query and parameters | Exact search terms, filters, match thresholds, type filters, jurisdiction filters and date/time of search. |
| Result | No match, potential match, possible match, false positive, relevant match or confirmed match. |
| Match IDs and evidence snapshot | Provider IDs, source links, screenshots, PDFs or other preserved evidence. |
| Disposition | Reasoned conclusion, reviewer, escalation status and next action. |
2. Negative result
A negative result should be documented, not merely assumed. The file should preserve the query, source, identifiers, parameters, date, visible result and analyst conclusion that no relevant match was identified.
3. Hit result
A hit must be resolved. The analyst compares identifiers, checks source reliability, reviews the underlying record, captures match IDs and explains whether the result is false positive, possible match, relevant match or confirmed match.
4. Escalation evidence
Escalation should include the reason, source evidence, unresolved questions, risk impact, recommended decision and reviewer approval. A handover to MLRO should preserve enough context for independent judgement.
5. Audit test
A second reviewer should be able to answer: what was checked, why, which sources were used, what was found, how the analyst resolved it, who approved the decision and when the next review is due.