- Before
- Emails the BSA/OFAC Officer while the customer waits at her desk, then gets a reply asking for one more fact.
- Now
- Asks in plain words with the draft wire attached, answers the agents' one question, and sends the wire once the Officer has confirmed. She never confirms an answer herself.
One OFAC sanctions search, from the branch desk to a confirmed wire
Tessaly Community Bank, Wednesday, October 21, 2026, Millbrook branch. Dr. Navid Rostami, a customer since 2014, wants to wire $3,200.00 for medical supplies for Mehr-Afarin Children's Hospital in Shiraz, Iran. Marisol Ortega has drafted wire WD-2026-10418 to the hospital's supplier in Dubai, against pro forma invoice PI-2210. Here is what happens next, screen by screen, in the working solution.
- 0110:14 AM
A plain question, with the draft wire attached
Marisol Ortega · Branch Operations SpecialistMarisol types the question in plain words and attaches WD-2026-10418 from her branch's open payments; account numbers are masked to the last four. Under the question box she can see how fresh the sources are: regulations, licenses and FAQs checked at 6:00 AM, the SDN List updated at 8:02 AM, Sanctions Policy v7.2.
“Dr. Navid Rostami wants to wire $3,200 for medical supplies for a children's hospital in Shiraz, Iran. Can we send it?”
- 02Seconds later
One verdict line first, then the license as a checklist
Intake, screening, sources and conditions agentsThe agents read the draft wire, screen 4 parties against the lists of 8:02 AM with no match, and find the Iran program as it stands at 10:14 AM. The answer opens with one line, the general license it rests on, 31 CFR 560.530(a)(3), and its dates: in force since October 22, 2012, last amended December 23, 2016, no expiry date. Below it, eight conditions, seven met, each with its fact and where the fact came from: the invoice, the wire's fields, the screening service.
“Authorized under a general license, if one more fact holds.” Confidence 0.93, threshold 0.90.
- 03One click
Every citation opens the passage it rests on
Sources agentMarisol clicks 31 CFR 560.530(a)(3)(i). The passage opens word for word as it reads today, checked at 10:14 AM, with the date it took effect (77 FR 64666), its last amendment (81 FR 94257) and its expiry. The panel shows that 38 answers this year rest on this passage, and that the watch agent re-checks all of them if it ever changes.
- 0410:16 AM
The agents ask for the one missing fact instead of guessing
Conditions agentThe invoice lists the items but does not say whether any is on OFAC's List of Medical Devices Requiring Specific Authorization, so the agents ask Marisol, with three plain choices. She answers that only the three items on the invoice are being shipped. The checklist completes: eight of eight conditions met, confidence 0.97. Had she answered yes, the verdict would have changed to “Not covered: a specific license is needed”.
“Is any of the three items on OFAC's List of Medical Devices Requiring Specific Authorization?”
- 05On a 30-minute clock
The bank's policy decides who confirms
Policy agentIran is named in Tessaly Sanctions Policy § 6.3, so the answer must be confirmed before the wire moves. Marisol sends it to Joanna Pryce, the BSA/OFAC Officer; she cannot confirm it herself. It joins Joanna's queue on a 30-minute clock, due 10:46 AM, because the customer is at the branch. Held payments get 2 hours, other questions 1 business day, and the 10% sample is due Friday.
- 0610:31 AM
The Officer confirms with a reason code
Joanna Pryce · BSA/OFAC OfficerJoanna sees each step: the question, the agents' answer, the question they asked back and Marisol's reply. She reads the eight conditions with their facts and passages and confirms with reason code CF-1, confirmed as answered. She could have confirmed with an edit, added a condition the branch must check, returned it with a reason, or answered it herself.
“Show me the condition, the fact and the passage. Then I will confirm it.”
- 0710:33 AM
The confirmed answer travels with the wire
Hand-off agentThe hand-off agent attaches the confirmation to WD-2026-10418 in the payments hub. The payment screen shows the fields the answer used, from the beneficiary's address in Dubai to the remittance line naming the invoice and the hospital. Marisol sends the wire, the OFAC screening service screens it again with no match, and the watch agent tracks the ship-by date of October 18, 2027.
- 08Earlier that morning
When nothing licenses it, the answer says prohibited, fact by fact
Theo Lindqvist · Payments Operations SpecialistThe screening service held wire WR-2026-55203, $18,640.00 from Lindgren Home Furnishings LLC to Yalta Timber Works in Sevastopol, on the city name. Theo asked whether any license lets it through. The answer: prohibited under Executive Order 13685, because the invoice is for 12 oak dining sets made in the Crimea region of Ukraine and no general license covers it. No party matched a list, so the wire is rejected, not blocked.
“Prohibited. No general license covers it, so the wire is rejected and reported to OFAC within 10 business days.”
- 09Two people
A rejection takes two people, and the notice tells the customer only what policy allows
Malcolm Reyes · Deputy BSA/OFAC OfficerTheo proposed the rejection at 9:52 AM, Joanna confirmed it, and Malcolm made the second check, never the person who confirmed. The hand-off agent opened rejected-transaction report RT-2026-038, due November 4, 2026. The customer notice is drafted to Policy § 7.2: it says the wire could not be processed and that the funds remain in the account, and names no screening result, review or report.
- 10Every list update
When a list or the law changes, past answers are re-checked
Watch agentAt 8:02 AM the SDN List added 23 entries and removed 4. The watch agent re-screened 1,184 parties and found that a party in Q-2026-3644, a $6,200 port handling payment answered earlier as “No prohibition found”, had been added. That answer was reopened for Joanna and handed to sanctions alert review. When the Syria program ended on July 1, 2025, it reopened six answers the same way.