BLACKFILE screens an individual or company against applicable sanctions sources and PEP categories, then resolves each material match by identifiers, period, connections and the context of the transaction.
The result shows what is confirmed, what is excluded, and which question a qualified lawyer should assess. It does not substitute for the decision of a bank, regulator or competent authority.
At the first step, do not send passport data or document scans. The type of subject, the jurisdictions of the transaction and the purpose of the check are sufficient.
MATCHES
IDENTIFIERS
REGIMES
PEP
SOURCE LOG
M-01Namesake from another jurisdiction× False positive
M-02Record with partially matching data? Potential match
M-03Confirmed PEP record for the person under verification= Confirmed identity
M-04Related company with incomplete control data! Legal applicability required
Each material match is resolved separately: some are excluded, some remain an open question for the lawyer.
02 / WHY A NAME SEARCH IS NOT ENOUGH
The same name may belong to different people. One subject may be recorded differently
Sanctions sources use different alphabets, transliterations, aliases and sets of identifiers. A search may return a namesake or miss a subject due to a different spelling. This is why a list of matches is the beginning of verification, not the result.
Automated list search, subject identification, match resolution, establishing PEP category, verification of owners and related structures, and legal assessment of applicability of the regime are different tasks. BLACKFILE covers the first five and explicitly indicates where the work of a qualified lawyer begins.
The absence of a match is not a certificate of safety, and a name match is not a confirmed risk.
03 / WHEN A CHECK IS NEEDED
When the cost of an unverified match is higher than the cost of verification
01
Before an international transaction
The parties, jurisdictions and subject of the transaction determine the applicable regimes.
02
Before payment
The system has shown a match, and it must be established whether it relates to the recipient.
03
When onboarding a new client
An initial check that resolves matches, not a list of possibilities.
04
When checking a counterparty
The entity, its owners and related structures are checked together.
05
When ownership changes
A change of control changes the picture of applicable regimes.
06
When PEP exposure is identified
The category and period determine the scope of additional measures.
07
When working through an intermediary
The entire chain of parties to the transaction is checked, not only the direct counterparty.
08
Before an investment
The entity's exposure affects the terms and structure of the deal.
09
On repeat verification of an existing relationship
Records and structures change: a past result has its own date.
10
After an update to a sanctions list
A change to a record requires a review of previously closed conclusions.
04 / MATCH RESOLUTION
How a single match becomes a verifiable conclusion
An anonymized example of match resolution. This is an editorial illustration of BLACKFILE's method, not a government, banking or restricted database: real records and client data are not shown here.
Entered query
Subject
Individual
First name
Sample assumed name
Year of birth
1971
Country
Jurisdiction A
Role
Director of counterparty company
Name and spelling variantsMatches in one of the transliterations=совпадает
Year of birth1958 against 1971≠не совпадает
CountryJurisdiction D against jurisdiction A≠не совпадает
Identification numberNot disclosed in the record-нет данных
Resolution result
Match excluded: year of birth and country diverge.
Regime and source
Official sanctions list applicable to the transaction
Date of listing and amendments
record date / date of last amendment
What this means for the client
The record does not relate to the person under verification and is not carried into the final conclusion.
Match resolution procedure
01The name and available identifiers of the subject are entered.
02Possible matches are obtained across applicable sources.
03Date of birth, country, address, registration number, role and associated persons are compared.
04Some matches are excluded as not relating to the subject.
05For the remaining match, the source, regime, date and confirmation level are recorded.
06Applicability of the regime to the transaction is referred as a question to a qualified lawyer.
A name match does not mean that the same person has been found, and the absence of a match is not a certificate of safety. Marked in red is the single match for which the question remains open and requires legal assessment. Applicability of the regime to a specific transaction is assessed by a qualified lawyer.
05 / WHAT IS CHECKED
Sources, identifiers and the context of the transaction
There is no single universal global list: the set of sources is determined by the parties, the transaction and the jurisdictions involved. The scope is agreed before work begins.
01
Sources and names
official sanctions lists relevant to the matter
name variants and transliterations
identifiers in the legally accessible part
the date of listing and subsequent changes to the record
02
Status and structure
PEP category
period of public function
owners and controlling persons
related structures
03
Context
material adverse media, verified against the primary source
context of the transaction
jurisdictions involved
06 / THE PEP LINE
PEP status requires additional measures, not an accusatory conclusion
The category determines the scope of additional measures and the depth of verification of source of funds and connections. No universal retention period for the status is established: the approach depends on the applicable regime and risk assessment.
01
Foreign PEP
A person entrusted with prominent public functions in another state.
What this changes: typically the highest level of additional measures and attention to the origin of funds.
02
Domestic PEP
Prominent public functions within the country where the transaction takes place.
What this changes: the scope of measures is determined by risk assessment and the requirements of the applicable regime.
03
International organisation PEP
Senior management functions in an international organisation.
What this changes: the period of the function and the connection of the role to the subject of the transaction are checked.
04
Family member or close associate
Relatives and persons connected to a PEP by business or other close relationships.
What this changes: the status extends to the connection, not to conduct: structures and joint interests are checked.
05
Former PEP
A person who has ceased to perform public functions.
What this changes: no universal retention period applies: residual influence and risk are assessed.
PEP status is not a sanction and does not by itself prove unlawful conduct. The category and measures are confirmed by the requirements of the applicable regime, not by a general rule.
SCREENING FILE
The value of the report lies not in the length of the list of matches, but in the fact that every material match has a source, a date and a clear status
07 / VERIFICATION PROCESS
A connected route from the entity to handover to the legal team
01Identification of the entity and the transaction.
02Determination of the applicable regimes.
03Verification of the sufficiency of identifiers.
04Search across official sources.
05Normalization of names and spelling variants.
06Resolution of matches.
07PEP category verification.
08Verification of owners and related structures.
09Secondary verification of a material match.
10Matrix of results and limitations.
11Referral to the legal team where required.
BLACKFILE does not remove entries from independent lists and does not issue a certificate of absence of sanctions. The legal applicability of the regime is assessed by qualified legal counsel, and the decision rests with the bank, regulator or competent authority.
08 / WHAT THE CLIENT RECEIVES
A material showing what has been closed and what remains open
Each material match is assigned a status, source and date; excluded matches are separated from unresolved ones, with legal questions set out separately.
R-01 / RESULT
Sanctions and PEP screening memo
A short summary: what was checked, what was excluded, what remains a question, and for whom that question matters.
R-02 / RESULT
Table of sources and dates
Which official sources were checked and as of what date for each.
R-03 / RESULT
Search variant log
Transliterations, aliases and spellings used in the search.
R-04 / RESULT
Match resolution record
How each material match was resolved and by which identifiers.
R-05 / RESULT
Confirmed and excluded matches
Two separate lists: what pertains to the subject and what is excluded, with reasoning.
R-06 / RESULT
PEP category and period
Category, period of public function and scope of additional measures under the applicable regime.
R-07 / RESULT
Map of related structures
Owners, controlling persons and related companies to the extent available.
R-08 / RESULT
Open questions, source log and limitations
List of missing data, source log and material currency date.
BLACKFILE does not issue a certificate of the absence of sanctions and does not make the decision on behalf of a bank, regulator or legal team.
09 / WHO THIS IS FOR
For those responsible for the transaction and the relationship
CL-01 / CLIENT
Compliance teams
How to close a match with documentation. Result - a match resolution record with sources and dates.
CL-02 / CLIENT
Legal teams
Where the question of regime applicability begins. Result - the factual part and a list of missing data.
CL-03 / CLIENT
Financial directors and treasury
Whether a payment can proceed and what stands in the way. Result - a status for each material match.
CL-04 / CLIENT
Investors and funds
What exposure comes with the subject and its structure. Result - a map of connected structures.
CL-05 / CLIENT
Companies at client onboarding
How to distinguish a namesake from the subject of the check. Result - cleared matches instead of a long list.
CL-06 / CLIENT
Family Offices
How to assess PEP exposure without accusatory conclusions. Result - category, period and required measures.
10 / COMPOSITE EXAMPLE
A name match turned out to be false, but the structure required a separate check
SP-01Sanctions & PEPComposite example
The cleared match and the open question on the structure are kept separate
Задача. Before a payment, the client's system flagged a match against a sanctions record. The date of birth and geography made it possible to clear the match for the individual. However, the company structure revealed another legal entity with a similar name and incomplete control data.
Результат. BLACKFILE separated the cleared match from the open question on the structure. The client received the source, the date and a list of data required for further legal assessment, without any statement on the applicability of sanctions.
The example is composite and does not describe an actual client. Illustrative image: the persons shown are not parties to an actual transaction.
11 / WORK MODEL
From enquiry to delivery of the material
01
Subject and transaction
Who the parties are, what the transaction is and which jurisdictions are involved.
02
Regimes and sources
Which official sources apply to this task.
03
Identifiers
Whether there is enough data to distinguish the subject from a namesake.
04
Search and normalization
Spelling variants, transliterations and aliases.
05
Resolving matches
Each material match receives a status and a rationale.
06
Transfer
A results matrix, limitations and questions for the legal team.
SINGLE→REVIEW→CYCLEThe exact scope and cost are determined after assessing the number of subjects and regimes. Timelines are calculated after the scope is agreed and the source data received; the cost does not include taxes or third-party expenses.
12 / FORMATS
Three screening formats
The format depends on the number of subjects, the number of applicable regimes, the depth of the structure and the need for repeat checks.
01
Single Object Screening
Individual quote after assessing the number of objects and modes
Timeframe is calculated after the scope is agreed and the source data received
Check against principal applicable sources with match resolution.
Included
one person or company
principal applicable sources
match resolution
brief screening memo
02Main engagement format
Sanctions and PEP Review
Individual quote after assessing the number of objects and modes
Timeframe is calculated after the scope is agreed and the source data received
Extended check against multiple regimes with a separate PEP line.
Included
object, owners and connected persons
multiple regimes
separate PEP line
full screening file
03
Portfolio or Counterparty Cycle
Individual quote after assessing the number of objects and modes
Timeframe is calculated after the scope is agreed and the source data received
Periodic screening with agreed risk tiering and escalation rules.
Included
multiple third parties
agreed risk tiering
repeat check
escalation rules
13 / LIMITATIONS
What the check establishes and what it does not do
Applicable regimes depend on the parties, transaction and jurisdictions. PEP status does not mean unlawful conduct, a similar name is not a confirmed match, and the absence of a record does not guarantee the absence of risk.
BLACKFILE does not remove entries from independent lists and does not issue a certificate of no sanctions.
the legal applicability of a regime is assessed by a qualified lawyer
the decision of a bank or regulator remains with the relevant organization
every material match is given a source, date and status
the result reflects the state of the sources as of the agreed date
No. A name match does not mean the same person or company has been found. Each material match is resolved against identifiers: date of birth, country, registration number, role and connections. Some matches are excluded, and for the remainder the source, regime and date are recorded.
No. PEP status is not a sanction and does not by itself prove wrongful conduct. It means that additional measures apply to the relationship, the scope of which depends on the category, the period of the public function and the requirements of the applicable regime.
No. A certificate of no sanctions is not issued: the absence of a record does not guarantee the absence of risk, and the state of sources changes. The report indicates which sources were checked and as of what date.
No. BLACKFILE does not remove records from independent lists and does not influence the decisions of the authorities that maintain them. The work is limited to establishing whether the record relates to the object and preparing the factual part for the legal team.
The relevant lawyer. BLACKFILE establishes the factual part - the identity of the object, the regime and source of the record, the period and context - and expressly places the question of applicability outside its conclusion.
Such a match is recognised neither as confirmed nor as excluded: it is given the status of a potential match. The report indicates exactly what data is needed to close the question and from whom it can be requested.
Yes, in the extended engagement format. Exposure often arises not from the object itself but from controlling persons and related structures, so they are checked together with the object to the extent data is available.
Yes, if the relationship continues. Records and structures change and lists are updated, so a past result has its own date. Frequency and escalation rules are agreed as part of the engagement format.
16 / DIRECT CONTACT
Describe the object and the transaction without transferring documents
At the first step, do not send passport data or document scans. The type of subject, the jurisdictions of the transaction and the purpose of the check are sufficient.
