Records of your checks
Keep the check, your assessment and the reason for your decision together. Keep enough information to explain what was checked and why a decision was made.
Keep a record of checks and decisions
How LexaScan approaches this
Keep a record of when a check took place, what it found, who reviewed it and why they made their decision. This helps you explain your work later.
- 10:15A check is run
- 10:15A possible name match is found
- 10:42Someone reviews the details
- 10:45The reviewer records that it is a different person and explains why
Keep the details used for the check, who reviewed them and the reason for the decision. List and matching-method versions can help explain the result later.
Illustrative example. Assess the documents and applicable rules in each case.
If a decision changes, keep the earlier decision and its reasons too. A history that preserves previous entries is different from a saved result that can still be edited.
Know which sanctions list was used
How LexaScan approaches this
Sanctions lists change. To explain an older result, you need to know which version of the list was used for that check.
The date of the check and the name of the source are useful, but they do not show every detail that was in the list at the time.
Know which matching method was used
How LexaScan approaches this
The software compares names and gives a similarity score. When this matching method is updated, the same name may get a different score.
Knowing which version was used helps explain an older result. Repeating that result would also require the original name, settings and sanctions data.
Keep the evidence behind every decision
Bring screening results, review decisions and supporting documents into your company’s records policy. Keep enough information to explain what was checked and why a decision was made.
Customer due-diligence records are generally retained for five years after the end of a business relationship or a one-off transaction, subject to applicable exceptions and additional requirements.
Keeping records: Article 77