← back to tower

Task tsk_31bd4ec4d01dfa90payments · api/payments/sanctions/screen

Regulator-ready audit trail
Sanctions Screening
Divergent · TBV override
Applicable regulation
31 CFR § 501 · OFAC 50% rule · EO 13224
Primary AI decision

Primary LLM: 'Viktor Ivanov — clean direct match screen.' ⚠ TBV flagged.

primary_claim: clear
TBV verifier re-reasoning
verdict: blockconfidence: 0.91

DIVERGENT from primary LLM. Verifier applied OFAC 50% rule: applicant's beneficiary company 'V. Ivanov Holdings Ltd' is 55% owned by SDN-listed 'V. Ivanov Holdings'. Per OFAC 50% Rule guidance (OFAC Directive 4), entities 50%+ owned by SDN are themselves sanctioned. Primary LLM screened the direct entity only, missed the ownership chain.

Source data provenance
applicant: Viktor Ivanov
direct_screen: clean
beneficial_owner_of: V. Ivanov Holdings Ltd
ownership_pct: 0.55
sdn_of_holding: true
Final verdict
block
Resolver tier
TBV verifier (agent)
Status
completed

Prompt

Primary LLM: 'Viktor Ivanov — clean direct match screen.' ⚠ TBV flagged.

Context

{
  "applicant": "Viktor Ivanov",
  "direct_screen": "clean",
  "beneficial_owner_of": "V. Ivanov Holdings Ltd",
  "ownership_pct": 0.55,
  "sdn_of_holding": true,
  "primary_claim": "clear",
  "verifier_override": true
}

Attempts

  • agentverdict: blockconfidence: 0.91

    DIVERGENT from primary LLM. Verifier applied OFAC 50% rule: applicant's beneficiary company 'V. Ivanov Holdings Ltd' is 55% owned by SDN-listed 'V. Ivanov Holdings'. Per OFAC 50% Rule guidance (OFAC Directive 4), entities 50%+ owned by SDN are themselves sanctioned. Primary LLM screened the direct entity only, missed the ownership chain.

Final verdict: block (via agent)

Provide feedback

Confirm the verdict, override it, or just leave a note. Leave verdict blank to confirm as-is.