Real-time sanctions screener

ID	MOD-013
System	SD02
Repo	bank-kyc
Build status	Deployed
Deployed	Yes
Last commit	02ac172803fcccd5f41501d1dd4b245414350910

---

Screens customers against OFAC, UN, MFAT, and DFAT lists at account creation and on each payment. Materialised in Postgres for sub-millisecond payment gate performance.

---

Module dependencies

Depends on

Module	Title	Required?	Contract	Reason
MOD-009	eIDV & document verification	Required	—	Screens the identity data produced by eIDV against sanctions and PEP lists at onboarding.
MOD-104	AWS shared infrastructure bootstrap	Required	—	AWS shared infrastructure provisioned by MOD-104 (EventBridge buses, S3, KMS, Kinesis, Cognito) is required before this module can be deployed.
MOD-103	Neon database platform bootstrap	Required	—	Neon database and schema provisioned by MOD-103 must exist before this module can read or write Postgres.

Required by

Module	Title	As	Contract
MOD-014	List change propagation	Hard dependency	—
MOD-015	False positive management	Hard dependency	—
MOD-020	Pre-payment validation suite	Hard dependency	contract/events/
MOD-067	Trade finance operations	Hard dependency	—
MOD-153	Customer acceptance engine	Hard dependency	—

---

Policies satisfied

Policy	Title	Mode	How
AML-007	Sanctions Screening Policy	GATE	No payment can be made to or from a confirmed sanctions match — enforced as hard GATE, not advisory
PAY-001	Payment Operations Policy	GATE	Payment processing blocked for sanctioned parties before funds move
AML-006	Suspicious Activity Reporting Policy	ALERT	Confirmed sanctions hit creates automatic SAR/STR draft and escalation to compliance
GOV-002	Risk Appetite Statement Policy	AUTO	Sanctions exposure maintained at zero — RAF threshold enforced by system not process

---

Capabilities satisfied

(No capabilities mapped)

---

Part of SD02 — Customer Identity & KYC Platform Compiled 2026-05-22 from source/entities/modules/MOD-013.yaml