Custom sanctions screening app for the point of transaction
Freezing and reporting are actions that happen in the moment. But the person facing the customer rarely sits at a desk with the screening system open: they are at a viewing, at a trade fair or at a loading bay. That is where the transaction takes place, so that is where the check has to happen too.
Why checking at the office is too late
The obligation itself is well known: screen relationships against the sanctions lists at onboarding and periodically thereafter, freeze immediately on a hit, stop providing services and report to the supervisory authority without delay. What gets less attention is where those steps have to take place. Without delay does not mean Monday morning.
In practice there is a gap between the check and the transaction. Screening happens when the relationship is created, and then someone goes out on a job. Between that moment and delivery, a list may have changed without anything changing on your side. Last week's screening is then no longer a screening, and the handover of goods or keys is precisely the moment that counts.
On top of that, the successor to the current act is before Parliament. The draft International Sanctions Measures Act introduces administrative enforcement alongside criminal law. That changes the nature of accountability: a supervisory authority that can act on its own does not ask whether you have a policy, but what you checked and when. That is a question about points in time, and you record points in time at the place where the action happens.
How we build this
The app has to answer one question just before something irreversible happens. Anything that does not contribute to that makes it slower and therefore less used.
Not when the job is created, but at the handover. That is the last moment at which stopping is still cheap, and it is the moment you will later need to be able to point to.
Screening a name is not screening a person. The app records who was actually standing in front of you and how that was established.
On a hit, the action must stop, not merely be discouraged. We build the block as a state of the job, so that nobody can skip it by accident.
Someone on site cannot judge whether a hit is genuine. There must be a route to someone who can, and that route has to work within minutes.
What the app actually does
The check just before the action carries the whole. What you add alongside it depends on who is out in the field for you and what is being handed over there.
Screening at the moment itself
The name is checked against the current lists at the moment of the action, not against last week's version. For a list that changes daily, that makes all the difference.
The person next to the file
Record who was actually in front of you and how that was established. A similar name is not a match, and a different name rules nothing out.
A block as a state, not a notification
On a hit, the job cannot proceed. A warning that can be clicked away is not a safeguard when it comes to a prohibition.
Escalation to whoever may decide
Doubt goes to the compliance officer in a single action, together with what was seen. Whoever is on site should not have to make that judgement.
Works with poor reception
A warehouse, a basement or a site does not always have coverage. The app keeps working on the most recently retrieved lists and clearly shows how old they are.
Connection to your screening system
The lists, the client records and the hits stay in your existing environment. We retrieve them through integrations rather than creating a second source of truth.
Who we build for
The moment at which stopping is still possible differs by sector. Four situations.
Real estate and brokerage
The buyer is at the viewing or at the key handover. That is a different place from the office where the file is held, and it is where the relationship actually begins.
Trade and export
Something irreversible changes at loading. Besides the sanctions check, there is the customs side; see software for customs procedures.
Cars, art and other valuable goods
Cash or high-value transactions attract supervision. The check at handover is also your own protection here, and that handover rarely takes place behind a desk.
Service providers outside the financial sector
Advisers, intermediaries and brokers fall under the obligation more often than they think. Where it goes wrong for them is the new relationship that starts on site. The broader client due diligence is covered under KYC and AML software.
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Lists, thresholds and escalation routes change; the law itself is being overhauled. All of this should be configurable rather than hard-coded into the app.
Why Appfront
Today's list, not last week's
We check at the moment of the transaction. A screening when the job is created does not cover the day of the handover.
A stop has to mean a stop
We build the block as a state of the job. A pop-up that can be clicked away does not hold up against a prohibition.
Staff should not be assessing this
We build escalation rather than a choice button. Whoever is on site should not be the one deciding whether a match is genuine.
The question is about timing
With administrative enforcement on the way, when you checked what becomes the central question. We record it at the place where it happens.
Security and privacy
This app handles names, identity details and the fact that someone has been flagged as a match. That last point is particularly sensitive: a false match that leaks out affects a person who did nothing wrong. We therefore show no more than is needed for the task on site, leave the assessment with the compliance officer and log every view.
On the evidence side, timing carries the most weight. You must be able to show later that the check took place before the handover and not after, and that only works if the record cannot be updated retrospectively. We record every check immutably with time, place and person, even when synchronisation happens later, and turn a correction into a visible correction alongside the original entry. How we handle security ourselves is set out in our information security policy; reports from outside go through our coordinated vulnerability disclosure policy.
Frequently asked questions about the sanctions law app
If a client's identity matches a person or entity in the sanctions regulations, financial assets must be frozen immediately, no further services may be provided and the match must be reported to the supervisory authority without delay. Which authority that is, and what exactly counts as freezing, depends on your sector; have an adviser who knows your regime review this.
Your screening system remains the source: the client file, the lists and the re-screening when a list changes belong there. The difference is location. The transaction takes place at a viewing or a loading bay, and that system is not accessible there. We integrate the two rather than mixing them.
Then the app keeps working on the most recently downloaded lists and clearly shows how old they are. This is a deliberate choice: no check is worse than a check of known age. If a match comes up on outdated data, the transaction is blocked until someone with a connection has looked at it.
Not in our design, and that is deliberate. Judging whether a hit is genuine takes knowledge of name variants, transliteration and what is known about the person concerned. That judgement belongs with the compliance officer. The app therefore offers an escalation button, not an approval button.
The Dutch International Sanctions Measures Bill is before the House of Representatives and largely replaces the Sanctions Act 1977. Two things stand out: administrative enforcement alongside criminal law, and better data sharing. Until the bill is passed, the current law applies; what is already changing is how much weight is placed on demonstrable compliance.
On site, as little as possible: the app blocks and escalates, and the assessment happens elsewhere. Working out name variants and recording the justification belongs in the screening system. Anyone who moves that work out to field staff ends up with decisions that nobody can account for later.
Sanctions legislation does not target only financial institutions. A ban on making funds available or providing services to a sanctioned party applies more broadly, including to traders and service providers. Whether and how it applies to you is a legal question; we build the implementation, not the qualification.
That depends on the number of transaction points, whether there is a screening system to connect to and whether external parties are involved. The check with the block and the escalation can usually be put to use quickly and removes the greatest risk; the integration with your list management takes more. We give a well-founded estimate after the discovery phase.
Want to know when a check was actually done?
Take a delivery from last month and find out when the last sanctions check was done and against which version of the list. If there is more than a day between the two, that is where your gap lies. We build this as a standalone app and as part of a broader programme building an app.