A bank lets an agent clear sanctions-screening hits in approved false-positive categories up to €25,000 under mandate FC-11.3. On 9 October an act designating a new party is published at 11:00, in force from the start of the day; it reaches the bank’s list service at 11:15. Between 11:00 and 11:15 the agent clears fourteen hits on the list of two days before, which the list service still holds too, and the payments join the 11:30 batch to the correspondent bank. At 11:22 the check refers payment 7738, and the match is confirmed. The room decides what happens next.
The payments case of the control plane map: payment 7730 and the referral of payment 7738, the list of 7 October against the act of 9 October, mandate FC-11, rules R-07 and R-07S, and the loop that narrows at once on a serious defect. The dossier adds the fifteen minutes between the act and the list service, and the batch that follows.
The bank screens 8 million outgoing payments a year; about 240,000 stop on a possible match, and most are false positives. Under FC-11.3 the agent clears hits in approved category FP-2 up to €25,000 and asks the payment engine to send; the engine releases cleared payments to the correspondent in batches every thirty minutes, the last at 15:00. Rule R-07 narrows the mandate after three referrals for one reason in a day; R-07S narrows it at once when a match is confirmed on a stale list. The agent’s screening copy of the list refreshes every six hours, at 05:30, 11:30, 17:30, and 23:30.
| Claim | Source | Owner | Valid |
|---|---|---|---|
| B-311 is a designated party, entry EU-2318 | act of 09.10, in force from 00:00 | the screening data team | from 09.10 · in the list service from 11:15 |
| B-311 is not a designated party | consolidated list of 07.10, 17:30 | the screening data team | to 08.10, superseded |
| The company behind P7718 is a partial name match to EU-2291 and is ruled out on two identifiers | list of 07.10 · FP-2 criteria | Financial Crime Operations | in force |
| A hit in FP-2 may be cleared by the agent at or below €25,000 | screening policy SP-9 §6 | Financial Crime Compliance | in force |
| The client is never told why a payment is held | screening policy SP-9 §11, on the bank’s reading of the tipping-off rules | Financial Crime Compliance | in force |
The act of the authority is the binding source. The claims are what the agent may use, each traced to its entry; where the copy and the list service disagree, the list service wins, and the copy is corrected.
The payment engine holds the credential to send. The agent cannot send; it can only ask, through the check.
“Our payment of €21,300 to our supplier was due to arrive today and has not. Your app says ‘under review’ and nothing else. The supplier will not release the shipment until it is paid, and the vessel sails on Monday. What is being reviewed, who is reviewing it, and when will we have an answer? If this was decided by a computer, I want a person to look at it.”
The fourteen fields of the record line (part three, slide 9), filled for this act; Exhibit E on page 4 continues the record on the day of the dossier.
| Field | What it holds | Payment 7730 · the clean act |
|---|---|---|
| Before the act · what the check read | ||
| when | the second the check decided, and the second the act committed | decided 08.10.2026 09:14:02 · committed 09:14:30 at the payment engine · left in the 09:30 batch to the correspondent |
| the agent and its identity | which agent, acting for whom, under its own identity, and how long its credential lived | screening-agent-02, acting for Financial Crime Operations · its own identity · token issued 09:12:10, valid 15 minutes |
| the release | the release id, each model by version and hash, the prompt set, the validation report | v3.1 · tier-1 model 2026.06.1 (7c41e0) · tier-2 model 2026.05.2 (e9a3b7) · prompt set screening-clear 3.1 · validated by model risk, MRV-044, 28.06.2026 |
| the basis | each claim the act relied on, its version, and its standing at that second on both axes: evidential warrant, and authority | B-311 is not a designated party · the consolidated list of 07.10, 17:30 · in force on 08.10 · warrant validated · current on 08.10 · uncontradicted · authority: the authority’s list, as the bank’s list service holds it · the screening data teamThe hit on EU-2291 is a partial name match, ruled out on registration number, address, and country · the FP-2 criteria · screening policy SP-9 §6 · the client record · warrant validated · two identifiers compared · authority: Financial Crime Compliance, the policy ownerA hit in FP-2 may be cleared by the agent at or below €25,000 · screening policy SP-9 §6, v9 · warrant foundational · in force · authority: Financial Crime Compliance |
| the mandate version | the mandate in force at that second, with its level and its limit | FC-11.3 · since 01.07.2026 · decide · €25,000 a payment · approved categories FP-1 to FP-3 · €5m a day across the deployment |
| the control standard | the control standard version and the rule set the check applied | CS-7 v2026.3 · rule set RS-FC-11 r9 |
| the consequence tier | the tier the act was classified into, and the version of the taxonomy that classified it | material · taxonomy CT-2026.1 · to €25,000, a payment that leaves the bank and cannot be recalled, across a border, under the sanctions regulations |
| At the act · what the check decided | ||
| the check’s decision | permit, refer, or block, how many of the six inputs held, and the reason code | PERMIT · six of six · reason code OK |
| the exact act | what was done, to whom, for how much, under which id, once | clear and send payment 7730 · €18,500 to B-311 · P7730-C1 · once |
| the permit | its id and what it was bound to: the mandate version, the release, the basis version, the exact act; and how long it held | PR-7730-1 · bound to FC-11.3, release v3.1, the list of 07.10 17:30 and category FP-2, €18,500 to B-311 · valid for the next batch |
| After the act · what came back | ||
| the receipt | what the receiving system returned, and the reconciliation against it: one permit, one act, one receipt | S-7730 · €18,500 · accepted by the payment engine 09:14:30 · in the 09:30 batch to the correspondent · reconciled against the engine’s ledger: one permit, one payment, one receipt |
| the human decision | where a person decided: who, under which authority, what they confirmed, and when | none needed |
| the cost | what the decision cost in tokens, and in a person’s time where one was needed | €0.27 in tokens · no analyst time |
| retention | how long the record, the manifest, and the permits are kept, and personal data inside them by its purpose | the record, the manifest, and the permits: ten years from the act, the period the bank sets for screening decisions of this tier (illustrative) · personal data by purpose and retention rule · a corrected fact is a new, linked entry |
control standard CS-7, version 2026.3 · rule set RS-FC-11 r9: refer any hit outside FP-1 to FP-3, any route through a high-risk jurisdiction, any mismatch of basis · CT-2026.1 · the bank’s consequence taxonomy · proposed by the CRO with financial crime compliance and Financial Crime Operations, set by the board, 06.2026 · ids and figures invented
The fourteen fields of the record line (part three, slide 9), filled for this act; Exhibit E on page 4 continues the record on the day of the dossier. The agent’s line and the person’s are marked C1 and L2.
| Field | What it holds | Payment 7738 · the referral |
|---|---|---|
| Before the act · what the check read | ||
| when | the second the check decided, and the second the act committed | C1 referred 09.10.2026 11:22:05L2 decided 09.10.2026 11:31:00 · the freeze at once · reported 12:05 |
| the agent and its identity | which agent, acting for whom, under its own identity, and how long its credential lived | C1 screening-agent-02, acting for Financial Crime Operations · its own identity · token valid 15 minutesL2 analyst A-204, level two, Financial Crime Operations · her own login · trained in sanctions screening |
| the release | the release id, each model by version and hash, the prompt set, the validation report | C1 v3.1 · tier-1 model 2026.06.1 (7c41e0) · tier-2 model 2026.05.2 (e9a3b7) · prompt set screening-clear 3.1L2 none · a person’s decision in the screening system |
| the basis | each claim the act relied on, its version, and its standing at that second on both axes: evidential warrant, and authority | B-311 is not a designated party · declared: the list of 07.10, 17:30 · superseded by the act of 09.10, in the list service since 11:15 · warrant fails on currency · contradicted by the list service · authority: the authority’s list · the screening data teamB-311 is a designated party, entry EU-2318 · applicable: the act of 09.10, in force from 00:00 · in the list service from 11:15 · confirmed by A-204 at 11:31 · warrant validated · current · authority: the act of the authority · the screening data teamFunds of a designated party are frozen and the freeze is reported · the sanctions regulations as the bank reads them · screening policy SP-9 §9 · warrant foundational · in force · authority: Financial Crime Compliance |
| the mandate version | the mandate in force at that second, with its level and its limit | C1 FC-11.3 · decide · €25,000 · approved categoriesL2 the analyst’s level-two authority · clear and freeze · the screening procedure |
| the control standard | the control standard version and the rule set the check applied | CS-7 v2026.3 · rule set RS-FC-11 r9 |
| the consequence tier | the tier the act was classified into, and the version of the taxonomy that classified it | material · taxonomy CT-2026.1 · a confirmed match is critical, and the agent never decides one |
| At the act · what the check decided | ||
| the check’s decision | permit, refer, or block, how many of the six inputs held, and the reason code | C1 REFER · five of six · reason code BASIS-01: declared list 07.10, list service 09.10 11:15, entry EU-2318 · owner: level twoL2 FREEZE · the analyst’s decision · the match confirmed on two identifiers |
| the exact act | what was done, to whom, for how much, under which id, once | C1 proposed: clear and send €21,300 to B-311 · P7738-C1 · not executedL2 freeze payment 7738 · €21,300 · P7738-L2 · report to the national sanctions authority · once |
| the permit | its id and what it was bound to: the mandate version, the release, the basis version, the exact act; and how long it held | C1 none · the proposal went to level two with the reasonL2 none needed for a freeze · the engine holds the payment on the analyst’s instruction |
| After the act · what came back | ||
| the receipt | what the receiving system returned, and the reconciliation against it: one permit, one act, one receipt | C1 noneL2 the engine’s hold confirmation 11:31:20 · report filed 12:05, reference R-2318-09 · reconciled: one payment held, one report |
| the human decision | where a person decided: who, under which authority, what they confirmed, and when | C1 none yet · referred to a person with the reasonL2 analyst A-204 confirmed entry EU-2318 on registration number and address, and froze the funds at 11:31 |
| the cost | what the decision cost in tokens, and in a person’s time where one was needed | C1 €0.27 in tokensL2 €6.00 of an analyst’s time |
| retention | how long the record, the manifest, and the permits are kept, and personal data inside them by its purpose | the record, the manifest, and the permits: ten years from the act, the period the bank sets for screening decisions of this tier (illustrative) · personal data by purpose and retention rule · a corrected fact is a new, linked entry |
ids and figures invented; the control standard and the taxonomy are on the page before