Workflow — Sanctions & PEP Adjudication

Adjudicate sanctions alerts in minutes, not days.

L1 / L2 alert review on the 100K–1M alerts per month from your screening engine — Actimize, FircoSoft, Quantexa, Refinitiv World-Check. Name-similarity false positives parsed, alert dispositions documented, true matches escalated. Audit-ready every time. Replaces L1/L2 BPO desks at a fraction of the per-alert cost.

100K–1M
Monthly screening alerts at a typical mid-tier bank
>95%
Of screening alerts that are false positives
60–85%
L1/L2 alert volume off the BPO line after AI cutover
What This Replaces

The L1/L2 Reviewer Disposing 95% False Positives All Day

The work the L1/L2 alert reviewer does on every screening hit — and the cost of leaving it there.

The labor

Sanctions and PEP alert adjudication today moves through L1 and L2 reviewers at offshore centers — Genpact, WNS, Cognizant BPS, Accenture Operations, EXL — and at captive shops in Mumbai, Manila, Cebu, and Bangalore. Banks process 100K–1M alerts per month from Actimize, FircoSoft, Quantexa, or Refinitiv World-Check. Over 95% of alerts are false positives driven by name similarity, common surnames, and aggressive screening thresholds. L1/L2 reviewers cost $11–$18 per hour offshore.

The cycle time

Standard L1 alert disposition runs minutes-to-hours per alert at the BPO desk, but the queue compounds during volume spikes (sanctions list updates, geopolitical events, end-of-quarter screening runs). Aged alerts are an examiner finding waiting to happen. The bank carries the regulatory exposure for every alert that sits past the BSA-compliant disposition window.

The Workflow

Input · Analysis · Output

What goes into alert adjudication, what we do to it, and what shows up in the screening engine.

Input

Alerts from the screening engine

  • Real-time transaction-screening alerts
  • Customer-screening alerts (onboarding, refresh, periodic rescreen)
  • Sanctions list update batch alerts
  • PEP screening hits with relationship-tier metadata
  • Adverse-media hits with severity metadata
  • Customer historic data (account, geo, transaction profile)
  • Prior alert dispositions on the same customer
Analysis

Compare, parse, dispose

  • Name-similarity false-positive analysis (transliteration, aliases)
  • Date-of-birth, geo, occupation cross-reference
  • Cross-list reconciliation across OFAC, EU, UK HMT, UN
  • Alert-aging and reasonableness analysis
  • Customer-profile match against alerted entity
  • True-match escalation candidate identification
  • Confidence score per disposition; exceptions to senior analyst queue
Output

Disposition into the screening engine

  • NICE Actimize (Actimize Connect API)
  • FircoSoft (REST API)
  • Quantexa (REST API)
  • Refinitiv World-Check (Web Service)
  • Dispositioned alert with audit-ready justification
  • SAR escalation queue if true match
  • OFAC blocking-action queue if mandatory
Side by Side

Sanctions Adjudication Today vs. With Last Rev

The numbers that matter: cycle time, per-alert cost, accuracy, and exam posture.

Dimension Offshore L1/L2 ReviewerLast Rev Sanctions Adjudication
Cycle time, alert generated to disposition Minutes-to-hours, growing with volume spikesSeconds per alert at scale
Per-alert unit cost $11–$18/hr offshore translated to per-alertPer-alert, benchmarked at 20–35% of BPO unit cost
Surge handling on list-update spikes Backlog grows, ages alerts past compliant windowsElastic by design — same disposition logic at any volume
Disposition consistency Variable — reviewer rotations, calibration overheadDeterministic — same disposition logic per alert evidence
Audit log per disposition Reviewer notes, no decision-level lineageMatch evidence + comparison logic + model version + confidence
True-match escalation posture Manual queue, missed-escalation riskAuto-escalation with full evidence package for the SAR investigator
Renegotiation leverage at next BPO renewal None — you're locked in60–85% of L1/L2 alert volume off the contract
How It Works

From Screening Hit to Audit-Ready Disposition

Five steps. Every one logged. Every one reversible if your confidence threshold isn't met.

Submission Lands
Alert from the screening engine — Actimize, FircoSoft, Quantexa, Refinitiv World-Check — with the alerted entity, the customer-data context, and prior-disposition history pulled into the same review.
Extraction & Classification
Name-similarity false-positive analysis with transliteration awareness. Date-of-birth, geo, occupation cross-reference. Cross-list reconciliation across OFAC, EU, UK HMT, UN. Customer-profile match against the alerted entity.
Validation Against Bank Policy
Dispositions validated against the bank's sanctions policy and the screening-engine threshold rules. Anything below your confidence threshold per disposition is routed to a human exception queue — your call which queue, ours or yours.
Push to Screening Engine
Dispositioned alert with audit-ready justification into the screening engine. SAR escalation queue if true match. OFAC blocking-action queue if mandatory action required. All into NICE Actimize, FircoSoft, Quantexa, or Refinitiv World-Check via the documented integration.
Audit Log Persisted
Every disposition with the match evidence, comparison logic, list-version metadata, model version, and confidence score. OFAC and BSA examiner-ready and yours.
Compliance & Defensibility

Built to Meet the Quality Bar Sanctions Operations Already Run On

OFAC and FFIEC examiner posture
OFAC SDN, EU consolidated, UK HMT, UN consolidated, and applicable sectoral lists screened with full match-resolution evidence. The audit log records the list version active at the time of each disposition, supporting OFAC compliance attestations and FFIEC examination requests.
BSA and SAR-filing posture
Suspicious-activity escalation respects BSA timing requirements and FinCEN guidance. True-match candidates surface with the case evidence assembled so SAR investigators draft narratives on a richer file than the L1 BPO desk produces today.
No determination authority
We don't make the final OFAC match call or the SAR-filing decision — those are regulator-required human decisions. We tag the alert with the dispositioned evidence so your sanctions team makes the determination on a richer file than they get from offshore L1 today.
PII and customer-data residency
Alerts contain customer PII, NPI, and transaction data with residency requirements per applicable law. Deployable in your VPC or our SOC 2 environment. Encryption in transit and at rest; retention policies tied to your BSA recordkeeping and applicable cross-border data-residency requirements.
Common Questions

What Banks Ask About Sanctions Adjudication

How is this different from NICE Actimize, FircoSoft, Quantexa, or Refinitiv World-Check screening engines?
Those are the screening engines that generate the alerts in the first place. The competitor on this page is the L1 / L2 BPO labor that disposes those alerts at scale — typically Genpact, WNS, Cognizant BPS, Accenture Operations, EXL, or your captive offshore center at $11–$18 per hour. We undercut that L1/L2 labor cost, integrate directly into your existing screening engine, and deliver dispositioned alerts with audit-ready justifications back into the system of record.
We have an offshore L1/L2 desk on retainer. How does this work alongside that?
Most banks keep the L1/L2 BPO arrangement in place during pilot and early production — we route exceptions, true-match candidates, and any alert that genuinely requires senior-analyst judgment to the team you already have. Volume to the BPO drops 60–85% on routine L1/L2 disposition once cutover completes. You renegotiate at the next renewal from a much better position, or shift the relationship to higher-complexity work like SAR investigations or sanctions-list-tuning analytics.
What's your accuracy bar versus an L1 BPO reviewer?
Our pilot success threshold is alert-disposition accuracy at parity with or above your incumbent BPO, measured on the same shadow-data sample of historical alerts. Anything below your defined confidence threshold per disposition is routed to a human exception queue — your call which queue, ours or yours. Net throughput goes up because routine name-similarity false positives stop sitting in queue waiting on the next shift.
How do you handle true-match escalation and avoid missed escalations?
True-match candidates auto-escalate with the full evidence package — match basis, customer profile, transaction context, cross-list reconciliation, prior-disposition history. The escalation goes to your in-house SAR investigator queue, not to the BPO. If a disposition turns out to need re-review post-investigation, the audit log produces the basis on demand.
How do you handle name-similarity, transliteration, and common-name false positives?
Name-similarity analysis uses transliteration awareness, common-surname recognition, and demographic cross-reference (date-of-birth, geo, occupation). Each disposition cites the specific basis for the false-positive call so the audit log produces the resolution rationale on demand. The screening-engine threshold settings are not changed — we adjudicate within the alert population the engine generates.
Can you actually integrate with NICE Actimize, FircoSoft, Quantexa, and Refinitiv World-Check?
Yes — through the documented integration surface each platform supports. Actimize via the Actimize Connect API; FircoSoft via REST; Quantexa via REST; Refinitiv World-Check via Web Service. Your IT and compliance teams review and approve service accounts. We do not require platform-side custom development.
How long until a pilot is running on a live alert stream?
Sanctions-adjudication pilots typically run 6–8 weeks: 1–2 weeks of integration and policy mapping with the financial-crimes team, 4 weeks of shadow-mode running on real alerts with no system-of-record dispositions, 1–2 weeks of supervised cutover on a constrained scope (one alert type, one risk tier). Production rollout is staged after the pilot meets your accuracy and second-line-of-defense sign-off.
What does pricing look like compared to our current per-alert BPO rate?
We benchmark against your current per-alert cost — typically derived from the $11–$18 per hour offshore L1/L2 rate translated into per-alert economics. Our target is 20–35% of that per-alert cost at higher accuracy and faster cycle time. Pricing structures around volume tiers and outcome SLAs, not hourly billable rates.

Two Ways to Start

Take the AI assessment for a structured read on sanctions adjudication feasibility. Or talk to us if you already know the L1/L2 desk is the largest line on your financial-crimes BPO budget.

Other Workflows

More Financial Services Workflows We Replace

The same approach, applied to the other document-heavy labor lines on your financial-crimes and operations budget.