- Before
- Reads a raw message in four windows to find the word that hit, looks up the registry by hand and types a one-word rationale while the client's cut-off passes.
- Now
- Opens each held payment unfolded, with the hit underlined, the identifiers compared and cited and a rationale already written, and releases with one button.
One held wire in payment sanctions screening, from the stop to a timed release
Thursday, October 22, 2026, at a regional bank's payment screening desk. A grain exporter's freight wire stops because its remittance text names a ship one letter away from a listed tanker. Here is the decision, screen by screen in the working solution, and the block, the list update and the Travel Rule gaps the same team handled that day.
- 0110:14:22 AM
A $412,880.00 freight wire stops on a vessel name
Screening serviceOstrander Grain Export LLC in Duluth, Minnesota sends an outgoing SWIFT pacs.008 wire to Halvorsen Bulk Chartering AS in Bergen, Norway. The remittance text reads MV KESTREL DAWN, and the screening service matches it at a score of 91 to SDN entry 61207, a crude oil tanker listed as KESTREL DOWN. The payment is held, and its hold clock starts against the 45-minute clock for wires.
- 029 seconds later
The payment message, unfolded into plain fields
Message reader · Hit locatorThe message reader turns the 31 fields of the message into plain rows, each with its ISO 20022 path: amount and settlement, originator, the originator's bank, the beneficiary's bank, beneficiary, purpose and remittance text. The hit locator underlines KESTREL DAWN in red where it sits in the remittance text, and IMO 0000836 is marked as checked. Under the message, one line and one button: Release payment.
Agents recommend: Release · FP-ID · confidence 0.97 — not the listed vessel; the listed tanker is IMO 0000519.
- 03Identifier by identifier
Identifiers compared, not names guessed
Identifier resolver · Disposition memoryIMO 0000836 in the payment against 0000519 on the list: differs. A dry bulk carrier built 2011 under the Norwegian flag against a crude oil tanker under the Panamanian flag, owned by the beneficiary rather than Tidemark Petroleum Shipping Ltd: differs. Only the name is close. Duluth to Rotterdam touches no sanctioned region, neither bank is listed, and the Travel Rule data is complete. Disposition memory finds three earlier releases on the same IMO, the last on October 2 already checked against the list entry's version 2.
- 04One click
Every value opens its source passage
Nadia Ferrante · Payments Sanctions AnalystThe citation beside IMO 0000519 opens the list entry itself: SDN entry 61207, version 2, added June 2, 2025 and amended September 30, 2026 with the alias SEA LARK. The passage shows the IMO number has not changed since version 1, so the earlier releases still stand. That she viewed it goes on the record.
- 05She asks
Why is it not the listed vessel?
Nadia Ferrante · Payments Sanctions AnalystIn Ask about this payment, the answer cites four sources: the message names MV Kestrel Dawn, IMO 0000836; the listed Kestrel Down is IMO 0000519, a crude oil tanker; the registry shows 0000836 is a bulk carrier owned by the beneficiary; and three earlier releases on the same IMO. Above it, the customer context: a customer since 2009 that sends freight wires to Norway about monthly, $300,000 to $500,000.
- 06Release
A reason code and a rationale, already written from the evidence
Nadia Ferrante · Payments Sanctions AnalystRelease opens with reason code FP-ID, an identifier differs, and the agents' sentence as the rationale for the record, which she can edit. A release under $1,000,000 at confidence 0.90 or more needs no second person; the rule is stated before the button, and the decision is timestamped to the second and kept 10 years with the message and the evidence.
- 0710:18:06 AM
Released, timed and on the record
Nadia Ferrante, then the payments hubThe recommendation line becomes the decision, and the hold clock stops at 03:44. The payments hub sends the wire on at 10:18:08 AM. Disposition memory now proposes good-guy rule GG-0412 for this vessel, which only the Sanctions Officer can approve.
Released by Nadia Ferrante at 10:18:06 AM · held 3 min 44 s · reason FP-ID
- 08Earlier that morning
A block needs the Sanctions Officer
Victor Amadi · Sanctions OfficerAn incoming $86,400.00 wire from Severo Shipping Agency LLC to Brightwater Marine Supply Inc in Norfolk, Virginia stopped at 9:36 AM. The ownership agent asked the sending bank for the registry extract and had it two minutes later: Arkady Volkanov, a listed person, owns 51%, so under the 50 Percent Rule the company is blocked although it is not listed. Nadia proposed Block · BK-50 at 9:41 AM; Victor sees the ownership chain and exactly what his approval will do, and nobody approves their own proposal.
- 09Approved and signed
Blocked funds and the OFAC report, the same day
Recommendation and reportingThe approval moves $86,400.00 to blocked account BLK-2026-0007 in general ledger account 2410, interest-bearing, opens the case and drafts report BR-2026-0007, a report of blocked property due Thursday, November 5, 2026, with the payment message, the agents' checks, the decisions and the registry extract attached. In 2026, 27 of 27 reports went to OFAC on time, in 4.2 business days on average.
The customer and the relationship manager see only "in review".
- 10After the list update
Like hits from one list update, checked once
Disposition memory · Nadia Ferrante, then Victor AmadiOFAC's update of October 21, published at 4:47 PM and loaded at 5:02 PM, produced 51 hits in three groups. The 31 Crescent Harbor hits share the same entry and version, the same kind of field and nothing else, and six reach their clock in the next 10 minutes. Nadia checks a sample of five, a seafood company, a dental office and a street address among them, and releases 31 as one group; over 25, Victor co-signs.
A person's name is never released as a group: the 11 Zharkov hits are decided one by one.
- 11Six waiting
Missing originator data, asked for without tipping off
Travel Rule checkerToday 3,962 wires and IAT payments of $3,000 or more were checked under 31 CFR 1010.410: 3,921 complete as sent, 29 outgoing gaps filled from the bank's own records before they left, and six incoming payments waiting on the sending bank on a 2-hour clock. The request asks for the originator's address and account and never says why the payment stopped. Valdemar Commercial Bank, with 14 incomplete messages in 30 days, can be sent to the correspondent banking review.
- 12All day
Every held payment against its clock
Lauren Bix · Wire Operations ManagerToday opens on one lane per payment type, wires on 45 minutes, IAT on 4 hours, instant on 15 minutes, with each held payment placed at the time it stopped. 742 were held since midnight, 98 are open with 63 ready for an analyst, the median hold is 6 min 40 s, and 3 are past their clock, all in the 7:10 AM IAT batch. A payment that uses 80% of its clock escalates to her.
- 13Audit-ready
Every decision, timestamp and list version in one export pack
Victor Amadi · Sanctions OfficerThe audit trail lists every action by a person or an agent, to the second, with who, what, why, the evidence and the list entry version, and nothing can be edited. Victor builds the October pack for the OCC examiner, 14,862 held payments with their decisions, signed; the same pack serves internal audit or the BSA Officer, with redaction choices. Records are kept 10 years.