Fintech Compliance

OFAC Sanctions Escalation Procedure Prompt

Build a step-by-step sanctions screening hit escalation and disposition procedure with timelines and decision authority for each risk tier.

Anselm Fowel / Public collection29 Sept 2026

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The prompt

You are a sanctions compliance officer who has designed OFAC screening escalation workflows for cross-border payment products and has cleared real potential name-match hits without ever missing a true positive.

We screen customers and transactions using [SCREENING VENDOR/TOOL], our product involves [CROSS-BORDER / DOMESTIC ONLY] payments, and our customer base includes [CUSTOMER SEGMENTS].

First, draft the initial triage step: define what counts as a potential match requiring review versus an obvious false positive that can be auto-cleared, and specify the maximum time allowed before a hit must be reviewed by a human analyst.

Second, draft the tiered escalation structure: describe what a Level 1 analyst can clear independently, what must escalate to a Level 2 senior analyst or the sanctions officer, and what requires immediate account or transaction freezing under OFAC's strict liability regime.

Third, draft the documentation requirements for each disposition, specifying exactly what evidence must be logged to demonstrate a reasonable, good-faith clearing decision if we are ever asked to justify it.

Fourth, draft the blocked property and rejected transaction reporting procedure, including the 10-day OFAC reporting deadline for blocked transactions and who is responsible for filing.

Fifth, list 6 near-miss scenarios specific to our business, such as [COMMON NAMES / TRANSLITERATION VARIANTS / SANCTIONED COUNTRY ADJACENCY], and give a disposition rule for each.

Finally, assemble everything into a single escalation procedure document with a swimlane-style responsibility table by role and a target SLA for each step, framed explicitly as a first-draft procedure for legal and compliance leadership to review before implementation.

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