A screening alert is a prompt for review, not a complete identity conclusion. Two people can share a name, while a person can appear under several names. Record the alert, compare relevant identifiers and explain the result. Keep PEP, sanctions and adverse-information questions distinct: a political role is not a sanctions prohibition, and a provider's similarity score is not a legal decision.
Preserve what produced the alert
Record the person or entity searched, the identifiers used, search date, provider or official source, list information and candidate result. Retain enough detail to understand the alert later without copying unnecessary personal data into general notes. Check whether the search used an abbreviated name, spelling variant or wrong date of birth. Correct the underlying customer information deliberately rather than selecting a convenient result and leaving the faulty data in place.
Compare identifiers rather than relying on a score
The DFAT Consolidated List includes identifiers such as aliases, birth details and citizenship. Compare available reliable information with the candidate record and note material matches, conflicts and missing facts. A different birth year may be relevant but should be assessed against the quality and alternatives in the source. Missing information is not a contradiction. Do not mark a result false positive merely because the customer denies being the listed person.
Escalate unresolved or confirmed sanctions concerns
DFAT advises seeking legal advice before dealings involving a matched listed person or their assets. A suspected freezable or controlled asset also has specific freezing and notification requirements. Follow the applicable sanctions response immediately; ordinary customer-risk approval is not a substitute. Keep an unresolved possible match visible and restrict relevant action while it is assessed. A provider's no-match outcome does not establish that every possible sanctions risk has been excluded.
Record the reviewer and what would reopen the case
For example, a shared name with independently supported different identifiers may justify a documented false-positive conclusion. State the evidence and limits rather than writing cleared without explanation. Assign any required review or approval, record the decision date and identify the conditions for reconsideration. Changed customer identifiers, new list information or a materially different service can require a new assessment. Keep the conclusion attached to the correct person, not every member of a related group.
Official sources
Confirm the current rules against these primary sources, last checked .
Questions
Does a high similarity score prove a sanctions match?
No. It is a review signal. Assess the source record and relevant identifiers, and escalate uncertainty under the applicable sanctions procedure.
Can a PEP result be handled as a sanctions ban?
No. The legal consequences differ. Apply the relevant PEP, enhanced-CDD and sanctions requirements separately.
Is a permanent false-positive exemption safe?
A conclusion depends on the evidence and candidate assessed. Record when changes in information or circumstances require it to be reconsidered.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
Keep reading
- Sanctions screening4 min
How Australian reporting entities screen against targeted financial sanctions, use the DFAT Consolidated List and integrate sanctions checks with AML/CTF.
- Adverse media checks4 min
How Australian reporting entities use adverse-media searches in AML/CTF without treating every negative article as an automatic risk result.
- Correcting a customer record3 min
Correct inaccurate customer information, reassess affected checks and retain the necessary history without treating an audit log as a reason to leave bad data in use.