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Banking AI agent · Sanctions

Sanctions-Alert Adjudication-Support AI Agent

Assemble what a screening hit turns on — the matched list entry, the message as sent, the customer record and the ownership position — with clearing, holding and release left to a sanctions analyst.

4–6 weeksTypical delivery
Your stackDeployment
Named analystClearing a hit
Agent CareAfter launch

What this agent does

Explains the match, clears nothing

In
01

Take the hits your screening raised — payment, customer and batch rescreen — with the list entry each one matched.

02

Attach the payment message as sent, and the bank's own record for the party that message names.

Reason
03

Set out which elements matched: name, spelling and script, birth date where the entry carries one, address, identifier.

04

Pull the history of the same match — what was found last time, and what has changed on the entry since.

05

Where the party is an entity, assemble the ownership and control position from the registers in scope.

Decide
06

Order the queue on the strength of the match and the deadline behind it, and mark what could not be settled.

07

Route clearance, hold, release and report decisions to the named person who owns each.

Out
08

Hand the analyst a pack — the entry, the elements, the message, the record and what is still unresolved.

09

Retain the hit, the evidence gathered, the rank, the analyst's decision and the reasons they gave for it.

Product statement

The agent assembles and orders. Clearing a hit, confirming a match, holding, releasing, rejecting or returning a payment, and reporting a match to any authority stay with named bank staff.

Example workflow

One screening hit, end to end

AgentHuman
1Hit receivedA payment, a customer record or a batch rescreen against the lists in scope
2Match set outWhich entry matched, on which elements, and how the list spells the name against the message
3Record and history pulledThe bank's own file for the named party, and what the same match returned when it was last worked
4Ownership position assembledWhere the party is an entity, who owns and controls it in the registers in scope, and where the chain stopped
No human action required

Stages 1 to 4 run before an analyst opens the queue — the entry, the message, the record and the ownership position are assembled first. Nothing in that stretch clears a hit, confirms a match or moves a payment either way.

5DecisionSplits on the strength of the match and the deadline running
Elements line up, and a deadline is running

Reaches the analyst at the top of the queue.

Thin overlap, or a match worked before

Waits in the queue, exactly as screening left it.

Sanctions analyst or sanctions officer

Reads the pack, decides whether the hit is a match, and owns the hold, the release, the report and anything said to the customer.

Investigate · Escalate · Refer
Disposition recorded — handed back
6Analyst decides, agent recordsOnly what a named person decided, with the reasons they gave, written where access and policy allow
7Outcome evaluatedHits a second reviewer reopened, payments released late, time to disposition and the reporting deadlines met
Reopened hits

A hit discounted that a later review reversed is counted as a failure.

What should not run autonomously

Human approval stays in control

Outside the boundary — human approval required8 items
Clearing a hit or discounting a match.
Confirming that a party is a listed person.
Releasing a payment that is held or blocked.
Holding, blocking or returning a payment.
Automation boundaryAgent acts unaided
Set out which entry matched, and on which elements.
Show the message as sent beside the bank's own record.
Assemble the ownership position and the earlier hits on this entry.
Rank the queue on match strength and the deadline running.
Write actions run only inside the approval boundaries agreed during implementation. Neither clearance nor release is one.
Reporting a match to any authority.
Telling a customer why a payment stopped.
Deciding an entity is owned or controlled.
Changing lists, matching rules or ranking.

Example output

One hit on one payment, annotated

Everything the agent assembles is attached to the hit and the message it came from.

Screening hit · single paymentIllustrative example
Hit source
Matched on
Message field
Elements aligned
Confidence
Disposition
Payment screening, pre-release
Name and country only
Ordering customer
Two of five compared
72%
None taken by the agent
As receivedThe hit, the entry as the list publishes it and the message as the sender wrote it — nothing on this side is inferred.
Evidence used Two spellings of one name Entry carries no birth date Ownership chain unresolved
Why it is ranked firstNo birth date on the entry, so two spellings and a country are the whole overlap.
ActionInvestigateEscalateRefer
What the score decidesWhere the hit sits in the queue and how soon an analyst opens it — not whether it is a match.

Value

Where AI adds value

The same four claims, placed at the point in the workflow where each one applies.

Where the value landsValue 01 – 04
Every hit screening raisesPayments, customers and batch rescreens
03Match & evidence

Show what the match rests on

Which entry matched and on which elements, how the list spells the name against the message, what the same match returned before, and who owns the party where it is an entity.

01Approved path

Work the hits holding money first

Hits are ordered on the strength of the match and on the payment sitting behind them, so the ones stranding somebody's money reach an analyst first.

02Human review

Name what could not be established

The identifiers the entry does not carry, the spelling that differs, the ownership layer that did not resolve — written into the pack rather than left to be noticed.

04Build an evidence trail

Retain the hit, the entry version it matched, the evidence assembled, the rank, the analyst's decision and the reasons they gave — on both paths.

Integrations

Typical integrations

Five system groups connect to the same agent. Which of them are in scope is decided in discovery.

Screening & filteringFircosoft · Bridger Insight · Actimize
Oracle Watchlist · hit queues
Lists & list feedsOFAC SDN · UK OFSI · EU consolidated
UN · list-distribution feeds
Payments & coreSwift MT and ISO 20022 · FIS · Fiserv
Temenos · repair queues

Agent

Sanctions-alert adjudication

Sets out the match
Assembles the record
Orders the queue

Customer & ownership dataKYC records · corporate registries
Ownership sources · case management
Observability & evaluationOpenTelemetry · Langfuse
Supported monitoring/evaluation sources

Integration availability depends on the client's existing systems and API access.

Agent controls

Six layers around a hit the agent cannot clear

Each control wraps the one inside it. The agent does not screen — it works the hits screening produced — and no hit leaves these layers cleared, held or released.

L6 · Outermost — last line of defenceInward → L1 · closest to the model
L6Rollback / safe modeHand the queue back to unaided analysts if evaluations or production signals degrade.Roll back
L5TraceabilityRecord the hit, the entry version, the evidence, the rank and the reasons given.Record
L4Disclosure limitsWhat a pack may say, and what may reach a customer, is set in advance.Limit
L3Disposition gateNo hit is cleared and no payment moved without a named sanctions analyst.Gate
L2Identifier testWhere the entry carries no birth date or identifier, the pack says so.Test
L1Match anatomyWhich elements matched is set out, rather than reduced to one score.Set out
Model corePack assembled — the entry, the elements matched, the message, the record and the rank
L1 – L2Show what the match actually rests on
L3Decides who may clear or release
L4 – L5Set what may be said and what is kept
L6Pulls automation back when signals degrade

How Nestack evaluates it

Evaluate what the analyst was not told — not only what the pack contained.

Coverage runs the whole depth of the workflow, and every layer is cut by slice.

Surface — the pack the analyst opens
Depth of coverage ▼
E1Pack-quality evaluationDid the pack hold what the analyst needed to decide the hit?
E2Match-anatomy evaluationWere the elements that matched, and those that did not, set out correctly?
E3Retrieval evaluationDid it read the right entry version, message fields and customer record?
E4Ownership evaluationWhere the chain stopped, was that stated rather than assumed?
E5Slice evaluationHow does performance change across specific hit cohorts?
E6Business outcomeTime to disposition, payments released late, and hits reopened on review.
Floor — the match not dressed as ordinary, and the payment not stranded

Failure modes

Where each failure originates in the agent

Seven failure modes plotted against the five stages of the agent lifecycle. Screening itself sits upstream of all five — the agent works the hits it produced, so nothing here claims a miss was caught.

Agent lifecycleDirection of processing →
01 · Hit intake1 mode
SN-01

Message never reached the pack

The screening extract is shown, not the wire as it was sent.

Stage gathersPayment, customer and batch-rescreen hits
02 · Match anatomy2 modes
SN-02

One name, two transliterations

List spelling and message spelling read as two parties.

SN-03

No birth date to separate them

A common name meets an entry that carries no identifiers.

Stage setsWhich entry matched, and on which elements
03 · Record & ownership2 modes
SN-04

Ownership stops at the named party

An unlisted company majority-owned by a listed one reads clean.

SN-05

Last disposition reused

The entry gained aliases since the same match was worked.

Stage assemblesThe customer file, prior hits and ownership
04 · Queue / handover1 mode
SN-06

A pack that reads like a clearance

The summary invites agreement and the analyst's reasons go unwritten.

Stage handsThe pack to an analyst, with nothing cleared
05 · Change / Version1 mode
SN-07

List moved, ranking not re-tested

A designation round reorders the queue and nobody re-measures.

Stage tracksList updates, matching rules and prompts
Sev-1 · a true match is made to look ordinary Sev-2 · a payment strands on a weak match Sev-3 · the analyst decides on a partial pack

Affected slices

The same person, spelled two ways

An exact hit on a domestic customer is close to a records check — one spelling, one file. What comes back unresolved is the name that crossed scripts on the way in, and the company nobody listed. Nestack reports by slice, not only in total.

Slice performance — reported separately, not only in aggregateIllustrative example
SliceFailure rateLift Lift vs. thresholdStatus
Transliterated and romanised names6.4%4.6× Review
Ownership and control hits3.9%2.8× Review
Cover payments, truncated fields2.7%1.9× Watch
Exact hits, domestic customers1.1%0.8× Normal
Bar: under-evidenced-hit lift vs. exact-hit baseline · scale 0–4.0× · tick marks the 2.0× review threshold 2 of 4 slices over threshold

Evidence-linked improvement

Nothing later proves a discounted hit was right

So the second pair of eyes is the evidence — the assurance sample, the entry amended after the fact, and the examiner who reads the same pack cold.

Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect

Reopened hits, assurance findings or late list amendments concentrate in one hit cohort.

02Diagnose

Read back against the entry as it stood that day — the elements compared, the message fields used, the register consulted.

03Improve

The comparison set, the ownership rule or the pack template is re-approved by the sanctions officer and version-linked.

04Verify

Re-assembled over hits already disposed of, including the ones a second reviewer disagreed with.

05Learn

The spelling that defeated the comparison is kept as a case, and the cohort it came from is re-tested before release.

Learn → DetectThe return edge. Lists are amended after the fact, so each cycle re-reads hits the last one disposed of against entries that have changed since.

Typical build scope

Twelve workstreams across six weeks

The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, screening and list access, match evidence and ownership, evaluation, the analyst queue, then production validation and handover.

Workstream Week 1Week 2Week 3Week 4Week 5Week 6
01Hit-queue discovery and boundary definition.
02Screening access and list-feed versioning.
03Hit taxonomy and pack-template design.
04Payment-message and customer-record retrieval.
05Match-anatomy and element comparison.
06Ownership and control assembly rules.
07Prior-hit history and re-alert handling.
08Held-payment deadlines and queue ordering.
09Pack wording and what may be said of a stop.
10Reopened-hit and assurance evaluation.
11Second-reviewer assurance and case handover.
12Observability, deployment and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel Final scope and sequence confirmed in discovery

Engagement tiers

What each tier includes

Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.

Capability✓ in scope · — not at this tier PilotOne list set, one hit queue ProductionProduction queue integration AdvancedMulti-entity / round-the-clock
Introduced at Pilot
Match anatomy, message and record in one pack
Ownership position and prior-hit history
Queue ranked on match strength and deadline
Named-analyst gate on clearing and release
Pack wording bounded by disclosure limits
Audit trail and baseline evaluation
Introduced at Production
Additional lists, channels and message types
Case-management and queue integration
Observability and evaluation
Introduced at Advanced
Multi-entity and multi-jurisdiction controls
High volume and round-the-clock cover
Build price From $5,000 From $8,000 Custom quote
Final build priceConfirmed after discovery based on the lists and channels in scope, screening and core integrations, message formats, hit volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.

What we need from you

What you bring, and what we build with it

Each input maps to a piece of build scope and a week in the delivery timeline.

You bringWe build with it
01A quarter of hits, with the disposition each one ended at Hit-queue discovery and boundary definitionWeek 1
02Your list feeds, and how fast a designation reaches them Screening access and list-feed versioningWeek 2
03The payment message as your systems store it, field by field Payment-message and customer-record retrievalWeek 2
04The depth your policy expects, and the registers you licence Ownership and control assembly rulesWeek 3
05A stopped payment, and the deadline that ran while it sat Held-payment deadlines and queue orderingWeek 4
06The wording an officer permits when a payment is stopped Pack wording and what may be said of a stopWeek 4
07The hits a second reviewer reopened, and what assurance saw Assurance-sample evaluation, then second-reviewer handoverWeeks 5–6
Nothing else is required Deployment, documentation and Agent Care handover are ours.

Delivery timeline

Four phases across six weeks

Phases are drawn over the weeks they actually occupy. Week 5 replays hits your analysts have already disposed of, so nothing live waits on the ranking.

Phase W1W2W3W4W5W6
Discovery W1
Build W2 – W3
Evaluate W4 – W5
Pilot & Launch W5 – W6
Week focus W1The hits in scope, who works them and who may clear one W2Screening access, list feeds and how a designation lands W3Match anatomy, record retrieval and ownership assembly W4Held-payment deadlines, pack wording and the evaluation suite W5Hits replayed against dispositions you have already made W6Second-reviewer assurance on live hits, then handover
Reading the bandOwnership assembly and the pack template finish before evaluation starts, because a pack that changes mid-test cannot be measured. The bars show that dependency, not a smooth ramp.
At the end of W6Live hits have been worked from the agent's queue under a second reviewer, the entries amended since disposition have been re-read, and Agent Care takes over monitoring.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.

Next step · Banking AI agent

Build an evidence agent around the lists you already screen against.

Show us a month of screening hits, how each one was disposed of and who is allowed to clear one. We'll rebuild that month and mark two things on every hit — the elements the pack could not establish, and the spellings and ownership layers a discounted hit was resting on.

Nestack Agents · Sanctions-alert adjudicationAGT-BK-09 · Agent Care available after launch