Sanctions screening

What do I do about a false positive in sanctions screening?

A false positive — an incorrect hit in sanctions screening — must be documented and resolved by hand. Check date of birth, address, nationality and other identifying details. Where it is unambiguously a different person, document how you resolved it and carry on with the transaction. Do not simply delete the hit.

False positives are common, particularly with widespread names ("Muhammad Khan", "Juan García"). The procedure:

  1. Do not ignore: no hit is simply deleted or overlooked — every hit is worked through.
  2. Manual review: compare all the available data: full name including middle names, date and place of birth, nationality, address, identifying numbers (passport number) and, where available, a photo comparison.
  3. Documentation: record the outcome, for example: "false positive on account of a differing date of birth (hit: 01.01.1970; client: 15.03.1985)".
  4. Reasoning: note briefly and comprehensibly why this is a different person.
  5. Retention: the false-positive documentation belongs in the KYC file and is retained with it.
  6. Where doubt remains: if the hit cannot be resolved clearly, bring in a compliance specialist or report the case to SEPBLAC as a precaution.

Legal basis: EU sanctions regulations; Ley 10/2010, Art. 42 (penalties)

Practical tip: Use a screening tool with a low false-positive rate. Checking lists by hand (Excel, PDF) has a high error rate — a semi-automated solution pays for itself.

AI-assisted tools were used in preparing these FAQs; the content was subsequently reviewed and approved by the Doxario editorial team. They reflect the general state of the law as at the review date shown and do not constitute individual legal or tax advice. To assess your own case — particularly where complex structures are involved (offshore companies, trusts, foundations, communities of heirs) or where the new EU rules leave room for doubt — we recommend consulting a lawyer specialising in Spanish anti-money-laundering law and, on tax questions, a tax adviser. Doxario is a deal management and compliance platform for estate agents in Spain, operated by Blue Pepper S.L.; we therefore have an economic interest in the solutions described in these FAQs. Doxario accepts no liability for decisions taken solely on the basis of these FAQs.

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