When an AML screening returns a confirmed sanctions match, a Sanctions Incident is created. As the brokerage admin, you handle the resolution. Incidents are admin-only - agents can't see or work them.
When An Incident Is Created
An incident is created automatically when a screening returns a confirmed sanctions match against any of the watched lists (OFAC, UN, EU, UK HMT, Canadian sanctions regimes, etc.). See What Lists Are Checked.
A potential/fuzzy match is not an incident - those return as Attention for broker review. Only confirmed matches escalate.
Immediate Effects
The moment a sanctions incident is created:
- You're notified as the admin.
- The client's record is flagged prominently in the broker's view.
- The broker who ran the screening is told that a serious result was returned and is escalated to you.
- Further work with the client is paused until the incident is resolved. Outreach can't be sent, reports can't be generated, portals can't be sent - everything's on hold.
Where Incidents Live
Go to Brokerage > Compliance > Sanctions. You'll see every open and recent incident.
The Incident Detail Page
For each incident:
- The match detail - which list, what the matched record looks like (name, dob, identifiers).
- The client's submitted info that triggered the match.
- Recommended next steps based on the type of match.
- Documentation space to record your investigation and decision.
Resolution Paths
Three primary outcomes:
Confirm The Match And Terminate
If you confirm the match is your client (a true positive), you typically need to terminate the relationship under sanctions law. Document the decision in the incident, including:
- The confirmation evidence.
- The date you terminated.
- Any reporting obligations you've fulfilled (FINTRAC suspicious transaction report, OSFI reporting, etc.).
Mark the incident as Confirmed - Terminated.
Document A False Positive
If the match is someone with a similar name but not your client, document the basis for that conclusion (e.g., date of birth differs, residence differs, no other identifiers align).
Mark the incident as False Positive - Resolved.
Mitigation (Rare)
For certain regimes there are license-permissive scenarios. These are rare and usually require legal advice. Document the legal basis and any license details.
Mark the incident as Mitigated - Documented.
After Resolution
Once resolved:
- The hold on the client's account is lifted (or, for terminated relationships, the client is removed).
- The incident is archived with a full audit trail.
- Future re-screenings will continue to flag the same match unless you've documented a false positive at the identity level.
Reporting Obligations
Some sanctions matches trigger external reporting obligations (FINTRAC, OSFI, RCMP depending on the regime). Those obligations are your responsibility as the brokerage's compliance lead. BrokerPlus surfaces the match; you handle the regulatory filings.
What To Do Next
- Read the broker-side overview: Sanctions Incidents.
- For PEP-driven escalations (different flow): Managing EDD Cases.