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Ustawi
Screening · 4 min read

How sanctions and PEP screening works

Ustawi screens clients against sanctions and politically-exposed-person (PEP) lists from inside the same platform the loan runs on, so a genuine hit is surfaced in the compliance workflow rather than lost between two disconnected tools. Screening never auto-clears or auto-rejects anyone — it raises an alert for a human decision.

When a client is screened

Screening runs against borrower identity data — and, where those apps are enabled, guarantor identity data — at onboarding, and can be configured to re-screen periodically. Because it draws on the NIDA identity information already captured during customer due diligence, screening does not ask staff to re-enter anything; it checks the record that already exists.

What a match looks like

A match (a screening hit) is a possible correspondence between a client's details and an entry on a sanctions or PEP list. A hit is not a conviction and not a determination — name overlaps are common. What the platform does is flag the possible correspondence and raise an alert, leaving the true-match judgement to a compliance reviewer.

The resulting alert

  • The alert is timestamped and attributed, so there is a record of when the hit was raised.
  • It is routed to designated compliance staff for review rather than shown to the originating officer as an open task.
  • It stays open until a compliance decision resolves it — the platform will not clear it automatically.
  • Every action on the alert is written to the audit log for the tenant and, on request, its supervisor.
A human decision is always required

The platform surfaces hits; it does not decide them. Whether a hit is a true match, and what to do about it, is a compliance judgement made by the tenant institution's own staff.

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