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Sanctions and PEP Screening Cycle

Example prompt: "Every week, run our active clients and their directors against the published sanctions and PEP lists. Log clean passes, draft an escalation memo for any possible match, and red-alert me in #compliance if a possible match is on cover or up for renewal."

The Problem

A broker writing commercial business has to satisfy itself that the entities it places cover for, and the people behind them, are not on the published sanctions lists or in the sensitive politically-exposed-persons category. The lists move — names are added every week, designations change, transliterations vary. The compliance officer is supposed to be re-screening the book at a sensible cadence, but in practice the only screening that happens is at onboarding, and a client added to a list a year after binding does not get caught until the next renewal goes through onboarding again — by which point the broker has been on cover for an entity it should not have been touching.

How GloriaMundo Solves It

We build a workflow that runs every Monday morning. An integration step reads the broker's Client Register and the Directors sheet — every active legal entity and every named individual. A web_search step fetches the latest published sanctions list snapshots from the official sources (the UK consolidated list and the EU/US equivalents the broker's procedure references). A code step runs each client and each director against each list using normalised name matching with date-of-birth and country-of-residence as tie-breakers, and classifies each result as Clean, Possible_Match, or Confirmed_Match. An LLM step drafts the escalation memo for each Possible_Match — names the client, summarises the matching list entry, lays out the specific points of similarity and difference, and proposes the next-step action (request additional ID, freeze the binder, escalate to senior compliance). An integration step writes the results to the Screening Log with the week's timestamp and posts a #compliance summary. Any Possible_Match touching a live or renewing policy red-alerts the compliance officer the same morning. Glass Box preview shows the memo drafts and the list checks before anything leaves the office.

Example Workflow Steps

  1. Trigger (scheduled): Every Monday at 7am.
  2. Step 1 (integration): Read the 'Client Register' tab — every active legal entity with name, registered_address, registration_number, country_of_incorporation. Read the 'Directors' tab — every named individual associated with an active client with name, date_of_birth, nationality, role.
  3. Step 2 (web_search): Fetch the latest published sanctions list snapshots — the UK consolidated list, the EU consolidated list, the OFAC SDN list, and any country lists the broker's procedure references — from the official government publication pages.
  4. Step 3 (code): Normalise names (lowercase, strip punctuation, transliterate to ASCII, expand common abbreviations) and run a fuzzy match of each Client Register and Directors row against each list. Use date_of_birth and country as tie-breakers. Classify each result as Clean (no match above the procedure-defined threshold), Possible_Match (above threshold, no perfect tie-breaker), or Confirmed_Match (full-name match with at least one tie-breaker).
  5. Step 4 (integration): Write the results to the 'Sanctions Screening Log' sheet with the week's timestamp, one row per (subject, list_source, result_classification).
  6. Step 5 (llm): For each Possible_Match and each Confirmed_Match, compose the escalation memo — names the subject, names the list entry, lays out the points of similarity (name parts, country, role context) and the points of difference (date-of-birth mismatch, country mismatch, distinct industry), and proposes the next-step action.
  7. Step 6 (integration): Save each escalation memo to the 'Sanctions' Drive folder under '[year]/[week]/[subject_ref].md' and post the memo as a Slack thread in #compliance under that week's summary.
  8. Step 7 (conditional + integration): For any Possible_Match or Confirmed_Match where the subject has a policy on cover or a renewal due inside the next 30 days, post a red alert in #compliance tagging the compliance officer with the subject name, the policy_number, and a link to the memo.
  9. Step 8 (integration): Post the weekly summary in #compliance — total subjects screened, lists checked, count of Possible_Match and Confirmed_Match results, count of red alerts raised. A clean week posts a one-line confirmation; a noisy week posts the full table.

Integrations Used

  • Google Sheets — the Client Register, Directors, Policies, and Sanctions Screening Log
  • Google Drive — the per-week memo folder under 'Sanctions/[year]/[week]'
  • Slack — the weekly summary in #compliance and the red alerts for live-cover matches
  • Web search — the official government publication pages for the consolidated sanctions and PEP lists

Who This Is For

Regulated brokers, MGAs, and risk managers placing commercial cover for clients with international footprints, named directors who may carry sanctions or PEP exposure, or business in sectors where list movement is frequent — and where the cost of being on cover for a sanctioned entity for even a fortnight outweighs the cost of a weekly screening pass many times over.

Time & Cost Saved

A compliance officer screening a book of 200 active clients and 600 named directors by hand against four published lists is a half-day every week, and in practice nobody on a busy desk runs it more than once a quarter. This workflow turns it into a 20-minute Monday morning review of the weekly summary, with the cases that actually need attention — the possible matches and the live-cover red alerts — already drafted with memos. The screening cadence shifts from quarterly-at-best to weekly, and the cases of new list additions to existing clients get caught within days rather than at the next renewal.