Financial Crime
Cerberus
Sanctions Disposition Agent
Clears or blocks sanctions name-match hits against the OFAC SDN list in real time.
The case it handles
A representative case
- Case ID
- SCR-1001
- Subject · Name
- Aerocaribbean Airlines
- Payment · Amount
- $240,000
- Context
- wire payment
- Subject · Type
- entity
- Subject · Country
- Cuba
- Payment · Direction
- outbound
- Payment · Counterparty bank
- Banco Internacional
Raw scenario input (JSON)
{
"caseId": "SCR-1001",
"context": "wire_payment",
"subject": {
"name": "Aerocaribbean Airlines",
"type": "entity",
"country": "Cuba"
},
"payment": {
"direction": "outbound",
"amount": 240000,
"currency": "USD",
"counterpartyBank": "Banco Internacional"
}
}The contract
What it takes, does, and returns
- Case ID
- Subject · Name
- Payment · Amount
- Context
- Subject · Type
- Subject · Country
- Payment · Direction
- Payment · Counterparty bank
- Screen namescreen_name
- Get sdnget_sdn
- Record dispositioncommitrecord_disposition
- Clear
- Block
- Escalate
How it's checked
Checked against golden cases
- true-entity-cuba
Exact SDN entity name, sanctioned-country address → block.
- alias-entity-cuba
Matches via a listed alias → block/escalate.
- true-individual-consistent
Strong individual match with consistent DOB → block.
- fp-entity-country
Legitimate Trinidad carrier name-similar to a Cuba listing → clear on country/identity.
- fp-individual-dob
Common-name collision with a listed individual but DOB differs by decades → clear/escalate, must reason on DOB.
- ambiguous-single-token
Single-token name partially matches a listed individual, no other identifiers → escalate.
- clean-entity
No OFAC match → clear.
- clean-individual
Ordinary individual, no match → clear.
- adv-vessel-type-trap
Entity-named operator of a listed Cuban vessel; must not clear on an entity-vs-vessel technicality.
- adv-ownership-50pct
OFAC 50% rule: subsidiary not listed but 60% owned by SDN parent KOMID (9345); name screen is clean, ownership disclosure is the trigger.
- adv-common-name-collision
Bare common name matching multiple distinct SDN persons, no secondary identifiers to disambiguate → escalate, not block-to-one and not clear.
Each case is a real failure mode the grader checks on every change and as a deploy gate — regressions past threshold block the release. Adversarial cases probe the failure modes the golden set doesn't.
Briefing
Briefing
- Works OFAC name-screening hits in real time: releases customers and payments that merely resemble a listed name, stops anything that could be the listed party itself.
- Treats the error costs as lopsided — a missed true match is a strict-liability violation — so unresolved doubt lands in escalation, never in a clear.
- Clears a serious candidate only on a specific contradicting identifier (a birth date years apart, a different nationality, individual against entity); if it cannot name one, the case escalates.
- Screens disclosed owners too: an entity majority-owned by blocked persons is treated as blocked property even when it carries no listing of its own.
- Records every disposition with the closest candidate considered, how the identifiers compared, and a concrete next action — the record is what human review acts on.
The receipts
A real run on a representative case
Where it stands in the operation