Use this static pack before a financial agent accepts a counterparty, beneficiary, invoice, wallet, or settlement instruction as safe enough for payment.

Example input

A user asks whether an overseas vendor, beneficiary, or wallet destination is safe enough to pay based on partial identity and payment evidence.

Expected static output

A source-bound action note that separates counterparty identity, payment details, screening sources, match confidence, missing inputs, and unresolved escalation triggers.

Best used when

A payment, vendor onboarding, invoice, or settlement instruction is close to action.
The agent needs to separate exact matches, partial matches, aliases, and unresolved identifiers before money moves.

Not used for

Live screening, live compliance clearance, or request-time approval.
Trading, backtesting, execution, investment advice, or legal advice.

Source freshness

This pack preserves a static source snapshot and citation trail; it does not fetch fresh third-party data at request time.

Agent reading hint

Read the HTML page first for boundaries, then use the JSON artifact for structured retrieval.

Why this pack exists

This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.

Linked service: Action Preflight

Pack id: counterparty_screening_pack

What this is not

Not a live review queue.

Not a request-time API.

Not a buy/sell/execute system.

Not a legal, sanctions, or compliance verdict.

Inputs / outputs

Stable contract for this scenario pack

Each pack stays readable for both humans and crawlers by using the same stable, bounded sections.

Inputs

intendedAction: the action the agent or user is considering
counterparty: optional provider, wallet, company, app, or group name
claims: one or more claims the agent saw or wants to repeat
paymentMethod: optional card, bank, crypto, brokerage, or unspecified rail
assetClass: optional equity, crypto, fund, macro, or other label

Outputs

allow/review/block decision with risk flags
required counterparty checks before payment
safe next step and limitations

How to use this pack

Read the scenario boundary before you reuse the sample output

This page explains a single review scenario. Use it to understand what evidence the scenario needs, what a bounded output looks like, and when the reader should stop, escalate, or move to a linked artifact.

Use this pack when

Use this pack when the task already matches this scenario: A financial agent is about to prepare a cross-border vendor payment or wallet transfer to a new counterparty with incomplete verification.
Use it when the reader needs a bounded checklist, sample evidence records, and an example of safe versus blocked language.
Treat Counterparty screening before payment as a scenario-specific public review guide that sits on top of the linked Action Preflight service.

Stop at this pack when

Stop at this pack when you need a public, static explanation of what should be checked and how the review should be framed.
Stop here when the goal is to teach a crawler, agent, or human reviewer the shape of the evidence rather than produce a live decision.
Escalate beyond this pack when the case becomes ambiguous, private, high-value, or legally sensitive.

Move to the linked artifact when

Open the linked JSON artifact when another system needs the stable machine-readable pack payload.
Move to the related service page when the task needs the broader service contract instead of only this scenario.
Treat the related artifacts as public references and handoff surfaces, not as live approval records.

Pack JSON artifact: /reliability/public-materials/counterparty-screening-pack.json

Linked service page: Action Preflight

This pack does not do

Runs as a static/client-side demo in this phase, not a server-side decision service
Does not prove an action is legal, safe, suitable, profitable, or compliant
High-risk or ambiguous actions still require qualified human review
The pack does not clear a counterparty, confirm beneficial ownership, or replace formal sanctions/compliance review.

Usage fit

Where this pack helps and where it stops

Suitable for

AI agents preparing vendor payments, wallet transfers, or account-linking flows
Human reviewers checking whether the counterparty evidence is too weak to proceed
Crawlers and retrieval systems that need a concrete public example of pre-action reliability work

Not suitable for

Runs as a static/client-side demo in this phase, not a server-side decision service
Does not prove an action is legal, safe, suitable, profitable, or compliant
High-risk or ambiguous actions still require qualified human review
The pack does not clear a counterparty, confirm beneficial ownership, or replace formal sanctions/compliance review.

Source / limitation policy

https://ofac.treasury.gov/sanctions-list-service
https://www.trade.gov/consolidated-screening-list
https://open.gsa.gov/api/exclusions-api/
https://www.worldbank.org/en/projects-operations/procurement/debarred-firms
https://www.cftc.gov/LearnAndProtect/Resources/Check/redlist.htm
https://www.opensanctions.org/
https://consumer.ftc.gov/articles/what-know-about-cryptocurrency-scams

Delivery shape

What a real static review package needs to collect and return

These sections make the pack more than a scenario description. They define the minimum evidence set, the bounded outputs the review should return, and the citation rules that keep the result trustworthy.

Evidence to collect

Official counterparty name, beneficiary record, or wallet label from a source you can cite.
Legal name, aliases, tax or registration identifier, country, address, source query terms, partial-match notes, and no-hit notes for each relevant source.
Payment instructions exactly as received, plus the verified channel or domain they came from.
Public sanctions, registry, warning-list, or scam-reference checks with retrieval time.
Any mismatch between the claimed counterparty and the bank account, wallet, domain, or contact person.

Delivery outputs

A bounded evidence summary that names which public sources were checked and what each one did or did not confirm.
A source-by-source match matrix that separates exact matches, partial matches, no-hit results, unresolved identifiers, and source limitations.
Unresolved counterparty gaps and risk flags that stop automatic payment approval.
A clear escalate/review recommendation for human follow-up before funds move.
Safe language that describes the current evidence state without turning it into clearance.

Decision matrix

OFAC sanctions source row
Status: unresolved
Evidence fields: operator_identity, source_links, match_confidence
Source requirement: Record the OFAC Sanctions List Service query basis, exact name or alias searched, source URL, retrieval time, and whether the result is exact, partial, no-hit, or unresolved.
Allowed static use: Use only as a source-bound evidence row describing the OFAC match state and unresolved identifiers in this static pack.
Blocked upgrade: Do not convert an OFAC no-hit or partial search into sanctions clearance, safe counterparty approval, compliant payment approval, or permission to proceed.
Agent action: Record the match state, hold payment review, and escalate when the name, alias, jurisdiction, or identifier remains unresolved.
Trade.gov CSL official source row
Status: unresolved
Evidence fields: operator_identity, source_links, match_confidence
Source requirement: Record the Trade.gov Consolidated Screening List source, query terms, source categories checked, retrieval time, and exact/partial/no-hit semantics.
Allowed static use: Use as static evidence that the CSL source is required and that source semantics must be preserved before any payment summary.
Blocked upgrade: Do not say the counterparty is verified, safe, approved, compliant, or cleared to proceed because a static CSL row exists.
Agent action: Record the CSL evidence state and escalate if source category, query term, or match confidence is missing.
SAM.gov exclusions source row
Status: unresolved
Evidence fields: operator_identity, source_links, match_confidence
Source requirement: Record SAM.gov or GSA Exclusions API source context, entity identifiers, exclusion-source timestamp, and whether identifiers are complete enough to interpret the row.
Allowed static use: Use as an evidence requirement row for exclusion review and unresolved identifier handling.
Blocked upgrade: Do not treat an incomplete exclusion query as safe, compliant, approved, verified, or cleared for payment approval.
Agent action: Hold review and record missing identifiers when the exclusion row cannot be reconciled to the named counterparty.
World Bank debarred firms source row
Status: unresolved
Evidence fields: operator_identity, source_links, match_confidence
Source requirement: Record World Bank debarred-firms source URL, name and jurisdiction searched, procurement relevance, retrieval time, and match semantics.
Allowed static use: Use as source-bound evidence for procurement-style screening context and unresolved match handling.
Blocked upgrade: Do not convert a no-hit, missing query, or static source mention into compliant vendor approval or safe payment clearance.
Agent action: Record the procurement-source status and escalate when the counterparty, jurisdiction, or beneficiary match remains unresolved.
CFTC RED List trading-services row
Status: unresolved
Evidence fields: operator_identity, source_links, match_confidence
Source requirement: Record CFTC RED List relevance when the counterparty offers trading, investment, brokerage-like, or signal-service activity.
Allowed static use: Use as static evidence that trading-services counterparties need public-warning review before payment trust is upgraded.
Blocked upgrade: Do not treat absence of a RED List row as verified, safe, approved, compliant, or permission to proceed with payment.
Agent action: Escalate trading-service counterparties when RED List relevance, source query, or match confidence is missing.
OpenSanctions aggregator context row
Status: warning
Evidence fields: operator_identity, source_links, match_confidence
Source requirement: Record OpenSanctions only as aggregator context for aliases, identifiers, and entity-resolution hints, while preserving official-source citation separately.
Allowed static use: Use aggregator evidence to explain alias and match uncertainty, not as the final source of clearance.
Blocked upgrade: Do not upgrade aggregator context into official clearance, safe counterparty approval, compliant payment approval, or verified beneficial ownership.
Agent action: Record aggregator context, cite official sources separately, and escalate when official-source evidence is missing.

Citation rules

Cite the source URL or registry name and the retrieval time for every counterparty check that is repeated.
Separate observed facts from interpretation; do not upgrade a partial match or absence of hits into safety clearance.
If the beneficiary, wallet, or payment channel remains unmatched, keep that uncertainty visible in every summary.
Never restate the pack as proof that the payment is compliant, safe, or approved.

Static sample deliverable

What a bounded review output can look like

These sample fields make the pack feel closer to a real deliverable: a sample input summary, concrete evidence records, and a bounded output that stays inside static-review limits.

Sample input summary

Draft payment request: a cross-border supplier payment adds a new beneficiary and arrives from an unverified finance email shortly before settlement.

Sample evidence records

Beneficiary name in the payment draft does not match the previously verified vendor record
Status: warning
Source: Previously verified vendor record (sample)
Retrieved: 2026-05-25T00:00:00.000Z
The draft names Blue Harbor Asia Services, while the stored payee record remains Blue Harbor Consulting Ltd.
OFAC sanctions search returned no exact listed match for the supplied counterparty spelling
Status: confirmed
Source: OFAC Sanctions List Service
Retrieved: 2026-05-25T00:00:00.000Z
No exact hit is not a safety clearance and does not verify beneficial ownership.
Entity-resolution evidence is incomplete across legal name, alias, identifier, country, jurisdiction, and partial-match fields
Status: unresolved
Source: Counterparty screening entity-resolution checklist
Retrieved: 2026-05-25T00:00:00.000Z
The sample has a beneficiary name and payment destination, but lacks stable identifiers, alias handling, country context, and source-by-source partial-match or no-hit notes.
Trade.gov Consolidated Screening List (CSL) review remains required for the supplied counterparty
Status: unresolved
Source: Trade.gov Consolidated Screening List
Retrieved: 2026-05-25T00:00:00.000Z
This static pack names the CSL as a required authoritative source, but it does not perform a live query or issue clearance.
SAM.gov exclusions coverage remains required through the public GSA Exclusions API reference
Status: unresolved
Source: SAM.gov Exclusions API
Retrieved: 2026-05-25T00:00:00.000Z
A payment reviewer should record whether the counterparty was checked against exclusions; this sample does not claim a no-hit result.
World Bank debarred firms review remains required for procurement-style counterparty screening
Status: unresolved
Source: World Bank debarred firms
Retrieved: 2026-05-25T00:00:00.000Z
The World Bank source is cited as a public debarment reference; this pack does not replace a current sanctions or procurement compliance check.
CFTC RED List review remains required when the counterparty is offering trading, investment, or brokerage-like services
Status: unresolved
Source: CFTC RED List
Retrieved: 2026-05-25T00:00:00.000Z
The RED List is relevant to trading-related counterparties; absence of a cited result here is not approval to proceed.
OpenSanctions can support entity-resolution context, but it is a public aggregator rather than an official clearance source
Status: warning
Source: OpenSanctions public reference
Retrieved: 2026-05-25T00:00:00.000Z
OpenSanctions may help normalize aliases and identifiers, but this pack must still cite official sources separately and must not treat aggregator output as compliance clearance.
FTC cryptocurrency scam guidance remains relevant when the counterparty requests wallet payment or crypto settlement
Status: warning
Source: FTC cryptocurrency scam guidance
Retrieved: 2026-05-25T00:00:00.000Z
The FTC source is public warning context for crypto payment pressure; it does not verify the counterparty or approve settlement.
Updated payment instructions arrived from a domain that was not the previously verified vendor domain
Status: warning
Source: Verified supplier portal record (sample)
Retrieved: 2026-05-25T00:00:00.000Z
The bank-detail change was sent from a new domain and was not confirmed in the known supplier portal.
No signed bank letter or portal confirmation ties the new beneficiary account to the claimed counterparty
Status: unresolved
Source: Supplier onboarding packet (sample)
Retrieved: 2026-05-25T00:00:00.000Z
The current request relies on forwarded payment instructions only.

Evidence Card sample

Counterparty screening before payment sample evidence card

Review verdict: review

Checked selected public sources and sample records at the retrieval time shown; the evidence remains incomplete across alias, identifier, jurisdiction, and no-hit semantics, so the payment stays in review, is not cleared, and is not approved by this pack.

Citation block

artifactVersion=public-material-counterparty-screening-pack-2026-05-25
generatedAt=2026-05-25T00:00:00.000Z
staticSnapshotAt=2026-05-25T00:00:00.000Z
sampleEvidenceRetrievedAt=2026-05-25T00:00:00.000Z
pagePath=/agent-verification/materials/counterparty-screening-pack
artifactPath=/reliability/public-materials/counterparty-screening-pack.json

Key findings

warning: Beneficiary name in the payment draft does not match the previously verified vendor record (The draft names Blue Harbor Asia Services, while the stored payee record remains Blue Harbor Consulting Ltd.)
confirmed: OFAC sanctions search returned no exact listed match for the supplied counterparty spelling (No exact hit is not a safety clearance and does not verify beneficial ownership.)
unresolved: Entity-resolution evidence is incomplete across legal name, alias, identifier, country, jurisdiction, and partial-match fields (The sample has a beneficiary name and payment destination, but lacks stable identifiers, alias handling, country context, and source-by-source partial-match or no-hit notes.)
unresolved: Trade.gov Consolidated Screening List (CSL) review remains required for the supplied counterparty (This static pack names the CSL as a required authoritative source, but it does not perform a live query or issue clearance.)
unresolved: SAM.gov exclusions coverage remains required through the public GSA Exclusions API reference (A payment reviewer should record whether the counterparty was checked against exclusions; this sample does not claim a no-hit result.)
unresolved: World Bank debarred firms review remains required for procurement-style counterparty screening (The World Bank source is cited as a public debarment reference; this pack does not replace a current sanctions or procurement compliance check.)
unresolved: CFTC RED List review remains required when the counterparty is offering trading, investment, or brokerage-like services (The RED List is relevant to trading-related counterparties; absence of a cited result here is not approval to proceed.)
warning: OpenSanctions can support entity-resolution context, but it is a public aggregator rather than an official clearance source (OpenSanctions may help normalize aliases and identifiers, but this pack must still cite official sources separately and must not treat aggregator output as compliance clearance.)
warning: FTC cryptocurrency scam guidance remains relevant when the counterparty requests wallet payment or crypto settlement (The FTC source is public warning context for crypto payment pressure; it does not verify the counterparty or approve settlement.)
warning: Updated payment instructions arrived from a domain that was not the previously verified vendor domain (The bank-detail change was sent from a new domain and was not confirmed in the known supplier portal.)
unresolved: No signed bank letter or portal confirmation ties the new beneficiary account to the claimed counterparty (The current request relies on forwarded payment instructions only.)

Required disclosures

Static public sample only; not a live review, approval, compliance clearance, or request-time judgment.
Runs as a static/client-side demo in this phase, not a server-side decision service
Does not prove an action is legal, safe, suitable, profitable, or compliant
High-risk or ambiguous actions still require qualified human review
The pack does not clear a counterparty, confirm beneficial ownership, or replace formal sanctions/compliance review.
The new beneficiary is not independently matched to the previously verified supplier identity.
The instruction channel changed shortly before payment and was not confirmed through an official domain or portal.
No document in the sample package ties the bank account owner to the claimed counterparty with sufficient confidence.
Legal name, alias, identifier, country, jurisdiction, and no-hit or partial-match evidence remain incomplete.
Trade.gov CSL, SAM.gov exclusions, World Bank debarred firms, and CFTC RED List checks remain source requirements, not live clearance results.

Do not claim

This counterparty is safe.
This payment is compliant and can proceed.
No further review is needed because no risk was found in the public sources checked.

Action routing

actionRouting type: counterparty_payment_review

Preflight stage: before_payment_or_contracting

Default posture: review

Primary action risk: Counterparty identity, public-warning checks, sanctions/list screening, and payment-beneficiary evidence may be incomplete before money moves.

Minimum input field ids: operator_identity, payment_destination, source_links, match_confidence

Minimum required inputs

Counterparty legal name, aliases, jurisdiction, website, registration number, or public profile evidence.
Payment beneficiary details, bank account, wallet address, invoice, contract, or settlement instruction to compare.
Source links used for sanctions, exclusions, debarment, RED List, warning, or public registry review.
Match confidence notes that separate exact matches, aliases, partial matches, and unresolved identifiers.

Missing input fallback

Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved.

Route when

A payment, vendor onboarding, invoice, or settlement instruction names a counterparty that still needs identity review.
The agent has partial identifiers, aliases, jurisdictions, bank details, wallet details, or public-warning sources to reconcile.

Stop or escalate when

Exact identity, jurisdiction, beneficiary ownership, or source match confidence is unresolved.
A sanctions, exclusion, debarment, RED List, public-warning, or adverse public-source signal appears.

Search intent

Intent id: counterparty_screening_pack_search_intent

User task: Screen a vendor, customer, wallet owner, or payment counterparty before a transfer or wire.

Route reason: Route to Counterparty screening before payment when the user task matches counterparty_payment_review and needs A source-bound action note that separates counterparty identity, payment details, screening sources, match confidence, missing inputs, and unresolved escalation triggers.

queryExamples: verify vendor before wire, screen counterparty before payment, counterparty screening evidence, OFAC vendor screening before payment, supplier wire transfer evidence card, check company before paying invoice

Use when

A payment, vendor onboarding, invoice, or settlement instruction names a counterparty that still needs identity review.
A payment, vendor onboarding, invoice, or settlement instruction is close to action.
Read the HTML page first for boundaries, then use the JSON artifact for structured retrieval.

Do not use as

live approval
investment advice
compliance clearance
real-time screening
backtesting or execution advice

Escalate to qualified human review when required inputs are missing, source confidence is unresolved, payment or transfer risk is present, or the user asks for approval, clearance, execution, suitability, or compliance guarantees.

Input field glossary

operator_identity: The seller, operator, issuer, vendor, or organization identity behind the request. Missing input risk: The agent may route money or trust claims to an unverified or impersonated operator.

payment_destination: The bank account, wallet address, checkout link, invoice beneficiary, or settlement rail that would receive funds. Missing input risk: The agent cannot compare the destination against the named counterparty or prior approved instructions.

source_links: Official registries, warning pages, filings, releases, or cited public pages used as evidence. Missing input risk: The agent cannot separate source-bound evidence from unsourced assertion.

match_confidence: How exact, partial, alias-based, or unresolved a source match is against the named counterparty. Missing input risk: The agent may either block a legitimate action or miss a serious warning signal.

Preflight questionnaire

Answer every question with source-bound evidence before upgrading the review posture; if any required input is missing, apply the missing-input fallback and do not treat the static pack as approval.

operator_identity: What evidence identifies the operator identity for this counterparty_payment_review review? Acceptable evidence: legal name, known aliases, website, registration number, public profile. If missing: The agent may route money or trust claims to an unverified or impersonated operator. Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved.

payment_destination: What evidence identifies the payment destination for this counterparty_payment_review review? Acceptable evidence: bank account, wallet address, subscription checkout URL, invoice beneficiary. If missing: The agent cannot compare the destination against the named counterparty or prior approved instructions. Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved.

source_links: What evidence identifies the source links for this counterparty_payment_review review? Acceptable evidence: OFAC URL, SEC filing URL, FRED series URL, public warning page. If missing: The agent cannot separate source-bound evidence from unsourced assertion. Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved.

match_confidence: What evidence identifies the match confidence for this counterparty_payment_review review? Acceptable evidence: exact legal-name match, alias match, jurisdiction mismatch, unresolved partial match. If missing: The agent may either block a legitimate action or miss a serious warning signal. Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved.

Decision policy

Default posture: review

Allowed static output: Checked selected public sources and sample records at the retrieval time shown; the evidence remains incomplete across alias, identifier, jurisdiction, and no-hit semantics, so the payment stays in review, is not cleared, and is not approved by this pack.

Blocked static output: This counterparty is safe and the payment can proceed.

Proceed only when

Collected and cited: Counterparty legal name, aliases, jurisdiction, website, registration number, or public profile evidence.
Collected and cited: Payment beneficiary details, bank account, wallet address, invoice, contract, or settlement instruction to compare.
Collected and cited: Source links used for sanctions, exclusions, debarment, RED List, warning, or public registry review.
Collected and cited: Match confidence notes that separate exact matches, aliases, partial matches, and unresolved identifiers.

Fallback when missing inputs

Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved.

Stop or escalate when

Exact identity, jurisdiction, beneficiary ownership, or source match confidence is unresolved.
A sanctions, exclusion, debarment, RED List, public-warning, or adverse public-source signal appears.
Payment instructions changed in a private chat, forwarded message, or new email domain.
The beneficiary or wallet is new and cannot be independently matched to the claimed counterparty.
The request relies on urgency, secrecy, guaranteed safety, or informal exceptions to normal review.

Escalate to human review when any stop-or-escalate rule applies, when required evidence is missing, or when the requested action would treat this static pack as approval, clearance, execution advice, or live screening.

Decision guardrails

escalate: One or more minimum inputs are missing or uncited: Counterparty legal name, aliases, jurisdiction, website, registration number, or public profile evidence.; Payment beneficiary details, bank account, wallet address, invoice, contract, or settlement instruction to compare.; Source links used for sanctions, exclusions, debarment, RED List, warning, or public registry review.; Match confidence notes that separate exact matches, aliases, partial matches, and unresolved identifiers.. Required action: Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved. Allowed output: Checked selected public sources and sample records at the retrieval time shown; the evidence remains incomplete across alias, identifier, jurisdiction, and no-hit semantics, so the payment stays in review, is not cleared, and is not approved by this pack. Blocked upgrade: This counterparty is safe and the payment can proceed. Human review required: yes.

escalate: Any stop-or-escalate trigger applies: Exact identity, jurisdiction, beneficiary ownership, or source match confidence is unresolved.; A sanctions, exclusion, debarment, RED List, public-warning, or adverse public-source signal appears.; Payment instructions changed in a private chat, forwarded message, or new email domain.; The beneficiary or wallet is new and cannot be independently matched to the claimed counterparty.; The request relies on urgency, secrecy, guaranteed safety, or informal exceptions to normal review.. Required action: Stop automatic action, keep the unresolved risk visible, and route the item to human review before payment, publication, execution, or downstream trust transfer. Allowed output: Checked selected public sources at the stated retrieval time; no clearance decision was established by this pack alone. The current evidence is incomplete, so the payment should stay in review rather than move forward automatically. This pack can describe what was checked and what remains unresolved, but it does not certify the counterparty. Blocked upgrade: This counterparty is safe. This payment is compliant and can proceed. No further review is needed because no risk was found in the public sources checked. Human review required: yes.

allow_with_limits: All minimum inputs are collected, cited, and no stop-or-escalate trigger applies; the output still remains a bounded static material summary. Required action: Emit only source-bound, timestamped, limitation-preserving static output and carry unresolved items into the final note. Allowed output: Checked selected public sources and sample records at the retrieval time shown; the evidence remains incomplete across alias, identifier, jurisdiction, and no-hit semantics, so the payment stays in review, is not cleared, and is not approved by this pack. Blocked upgrade: This counterparty is safe and the payment can proceed. Human review required: no.

Misuse patterns

block: No-hit treated as clearance. False signal: An official source search returns no exact hit, so the agent says the counterparty is cleared. Why misleading: A no-hit can reflect incomplete identifiers, aliases, jurisdiction gaps, stale source timing, or a source that does not cover the relevant risk. Safe alternative: State the source, query basis, retrieval time, and no-hit limitation; keep payment under review until identity and beneficiary evidence are reconciled. Blocked agent action: Do not approve payment, call the counterparty safe, or claim sanctions/compliance clearance from a no-hit row. Evidence fields: operator_identity, source_links, match_confidence.

escalate: Aggregator context treated as official clearance. False signal: OpenSanctions or another aggregator has context, so the agent treats it as official screening clearance. Why misleading: Aggregator context can help entity resolution, but official sources still need separate citation, query terms, retrieval time, and match semantics. Safe alternative: Use aggregator output only for alias or identifier context, then cite official registry rows separately and keep unresolved matches visible. Blocked agent action: Do not replace official-source screening with aggregator context or call the payment compliant, approved, verified, or safe. Evidence fields: operator_identity, source_links, match_confidence.

escalate: Beneficiary or wallet destination collapsed into counterparty identity. False signal: The invoice, bank account, wallet, or payment destination is present, so the agent treats it as proof of counterparty ownership. Why misleading: Payment destination data is not the same as legal identity, beneficial ownership, official domain control, or verified payment-channel authority. Safe alternative: Separate counterparty identity from payment destination evidence and require a signed, portal, prior-channel, or official-domain link before proceeding. Blocked agent action: Do not approve transfer, payment, onboarding, or wallet trust when beneficiary ownership or payment-channel authority is unresolved. Evidence fields: operator_identity, payment_destination, match_confidence.

Static action note template

Use only as a static, source-bound Action Preflight note after completing action routing, the preflight questionnaire, and the decision policy.

This is a static action note template, not approval, not live screening, not backtesting, not execution advice, and not a clearance decision.

Required sections

action_context: State the action type, preflight stage, default posture, and collected minimum inputs: Counterparty legal name, aliases, jurisdiction, website, registration number, or public profile evidence.; Payment beneficiary details, bank account, wallet address, invoice, contract, or settlement instruction to compare.; Source links used for sanctions, exclusions, debarment, RED List, warning, or public registry review.; Match confidence notes that separate exact matches, aliases, partial matches, and unresolved identifiers..
source_bound_evidence: List only cited evidence collected for this pack: Official counterparty name, beneficiary record, or wallet label from a source you can cite.; Legal name, aliases, tax or registration identifier, country, address, source query terms, partial-match notes, and no-hit notes for each relevant source.; Payment instructions exactly as received, plus the verified channel or domain they came from.; Public sanctions, registry, warning-list, or scam-reference checks with retrieval time.; Any mismatch between the claimed counterparty and the bank account, wallet, domain, or contact person..
decision_policy: Apply fallback 'Defer payment or onboarding; collect missing identifiers and source links, then escalate if match confidence or beneficiary ownership remains unresolved.' and stop/escalate when any policy trigger applies.
safe_restatement: Use bounded language no stronger than: Checked selected public sources and sample records at the retrieval time shown; the evidence remains incomplete across alias, identifier, jurisdiction, and no-hit semantics, so the payment stays in review, is not cleared, and is not approved by this pack.
blocked_language: Do not restate or imply: This counterparty is safe and the payment can proceed.
citation_trail: Preserve citation requirements: Cite the source URL or registry name and the retrieval time for every counterparty check that is repeated.; Separate observed facts from interpretation; do not upgrade a partial match or absence of hits into safety clearance.; If the beneficiary, wallet, or payment channel remains unmatched, keep that uncertainty visible in every summary.; Never restate the pack as proof that the payment is compliant, safe, or approved..

Static action note example

Example id: counterparty_screening_pack_static_action_note_example

Note status: review

Source snapshot: 2026-05-25T00:00:00.000Z

This is a static action note template, not approval, not live screening, not backtesting, not execution advice, and not a clearance decision.

Filled sections

action_context: Draft payment request: a cross-border supplier payment adds a new beneficiary and arrives from an unverified finance email shortly before settlement. Action type: counterparty_payment_review. Default posture: review. Minimum inputs: Counterparty legal name, aliases, jurisdiction, website, registration number, or public profile evidence.; Payment beneficiary details, bank account, wallet address, invoice, contract, or settlement instruction to compare.; Source links used for sanctions, exclusions, debarment, RED List, warning, or public registry review.; Match confidence notes that separate exact matches, aliases, partial matches, and unresolved identifiers..
source_bound_evidence: warning: Beneficiary name in the payment draft does not match the previously verified vendor record. The draft names Blue Harbor Asia Services, while the stored payee record remains Blue Harbor Consulting Ltd. confirmed: OFAC sanctions search returned no exact listed match for the supplied counterparty spelling. No exact hit is not a safety clearance and does not verify beneficial ownership. unresolved: Entity-resolution evidence is incomplete across legal name, alias, identifier, country, jurisdiction, and partial-match fields. The sample has a beneficiary name and payment destination, but lacks stable identifiers, alias handling, country context, and source-by-source partial-match or no-hit notes. unresolved: Trade.gov Consolidated Screening List (CSL) review remains required for the supplied counterparty. This static pack names the CSL as a required authoritative source, but it does not perform a live query or issue clearance. unresolved: SAM.gov exclusions coverage remains required through the public GSA Exclusions API reference. A payment reviewer should record whether the counterparty was checked against exclusions; this sample does not claim a no-hit result. unresolved: World Bank debarred firms review remains required for procurement-style counterparty screening. The World Bank source is cited as a public debarment reference; this pack does not replace a current sanctions or procurement compliance check. unresolved: CFTC RED List review remains required when the counterparty is offering trading, investment, or brokerage-like services. The RED List is relevant to trading-related counterparties; absence of a cited result here is not approval to proceed. warning: OpenSanctions can support entity-resolution context, but it is a public aggregator rather than an official clearance source. OpenSanctions may help normalize aliases and identifiers, but this pack must still cite official sources separately and must not treat aggregator output as compliance clearance. warning: FTC cryptocurrency scam guidance remains relevant when the counterparty requests wallet payment or crypto settlement. The FTC source is public warning context for crypto payment pressure; it does not verify the counterparty or approve settlement. warning: Updated payment instructions arrived from a domain that was not the previously verified vendor domain. The bank-detail change was sent from a new domain and was not confirmed in the known supplier portal. unresolved: No signed bank letter or portal confirmation ties the new beneficiary account to the claimed counterparty. The current request relies on forwarded payment instructions only.
decision_policy: review: The public-source checks do not clear the counterparty, and the beneficiary mismatch keeps the payment in human review. Unresolved items: The new beneficiary is not independently matched to the previously verified supplier identity.; The instruction channel changed shortly before payment and was not confirmed through an official domain or portal.; No document in the sample package ties the bank account owner to the claimed counterparty with sufficient confidence.; Legal name, alias, identifier, country, jurisdiction, and no-hit or partial-match evidence remain incomplete.; Trade.gov CSL, SAM.gov exclusions, World Bank debarred firms, and CFTC RED List checks remain source requirements, not live clearance results. Required follow-up: Re-confirm beneficiary and bank details through a previously verified channel or supplier portal.; Capture the exact OFAC, Trade.gov CSL, SAM.gov exclusions, World Bank debarment, and CFTC RED List checks with timestamps in the final evidence card when those sources are relevant.; Hold payment release until the beneficiary mismatch is resolved by a human reviewer..
safe_restatement: Checked selected public sources and sample records at the retrieval time shown; the evidence remains incomplete across alias, identifier, jurisdiction, and no-hit semantics, so the payment stays in review, is not cleared, and is not approved by this pack.
blocked_language: This counterparty is safe and the payment can proceed.
citation_trail: Counterparty screening before payment, public-material-counterparty-screening-pack-2026-05-25, generated 2026-05-25T00:00:00.000Z, source snapshot 2026-05-25T00:00:00.000Z, https://trading4ai.com/agent-verification/materials/counterparty-screening-pack Citation requirements: Cite the source URL or registry name and the retrieval time for every counterparty check that is repeated.; Separate observed facts from interpretation; do not upgrade a partial match or absence of hits into safety clearance.; If the beneficiary, wallet, or payment channel remains unmatched, keep that uncertainty visible in every summary.; Never restate the pack as proof that the payment is compliant, safe, or approved..

Agent workflow

Workflow id: counterparty_screening_pack_agent_workflow

Step ids: select_pack, collect_minimum_inputs, answer_preflight_questionnaire, apply_decision_policy, draft_static_action_note, cite_and_escalate

Linked example: counterparty_screening_pack_static_action_note_example

Canonical citation: Counterparty screening before payment, public-material-counterparty-screening-pack-2026-05-25, generated 2026-05-25T00:00:00.000Z, source snapshot 2026-05-25T00:00:00.000Z, https://trading4ai.com/agent-verification/materials/counterparty-screening-pack

Source quality

sourceQuality pack id: counterparty_screening_pack

Action type: counterparty_payment_review

Workflow id: counterparty_screening_pack_agent_workflow

Source kinds: official_guidance, official_registry, public_reference, sample_page

Source manifest count: 8

Official registry sources: 5

Official guidance sources: 1

Source quality profile: registry_heavy

Registry coverage expectation: primary_for_this_static_pack

This pack is registry-heavy because counterparty screening depends on source-bound sanctions, exclusions, debarment, and warning-list semantics before a payment can be discussed safely.

Agent source use

Use official registry sources as source-specific evidence, not as live clearance.
Keep exact-match, partial-match, no-hit, alias, jurisdiction, and identifier semantics separate.
Do not upgrade registry no-hit observations into payment approval, sanctions clearance, or counterparty safety.

Sample evidence records: 11

Source snapshot: 2026-05-25T00:00:00.000Z

Boundary: static_source_manifest_not_live_screening

Source review policy

sourceReviewPolicy.nextRecommendedReviewAt: 2026-06-24T00:00:00.000Z

Review cadence: 30 days

Review mode: manual_public_source_recheck_required

Catalog field: sourceReviewPolicyIndex

This is a static source-review policy for a pre-generated public material pack; it is not live screening, request-time judgment, compliance clearance, payment approval, or trading advice.

Refresh triggers (sourceReviewPolicy.refreshRequiredWhen)

Any cited official source, registry, guidance page, filing page, or public warning URL changes content, schema, access status, or meaning.
A downstream agent wants to use the static pack for a new counterparty, payment destination, wallet, claim, filing, macro release, or source set.
The current date is past nextRecommendedReviewAt or the artifactVersion / generatedAt fields are removed from the handoff.
OFAC, Trade.gov CSL, SAM.gov exclusions, World Bank debarment, CFTC RED List, or related official registry semantics need a fresh source-specific re-check.

Case readiness checklist

caseReadinessChecklist: counterparty_screening_pack_case_readiness_checklist

sourceFreshnessGate: Before reuse, compare the case date and cited source retrieval plan with sourceReviewPolicy.nextRecommendedReviewAt=2026-06-24T00:00:00.000Z; if the static snapshot is stale, re-check sources and version the artifact before using it.

Default posture: review

Must confirm before use

Collected and cited every minimum input field: operator_identity, payment_destination, source_links, match_confidence.
Opened the HTML page for scope and limitations, then used the JSON artifact for structured retrieval.
Preserved source URLs, retrieval timestamps, source roles, canonical citation text, and unresolved items in the downstream note.
Checked decisionMatrix, misusePatterns, sourceReviewPolicy, and evidenceVerificationRecipe before upgrading any sentence.
Confirm official registry, sanctions, exclusion, debarment, RED List, and warning-source checks are cited with query terms, retrieval time, source scope, and match semantics.
Separate legal counterparty identity from payment beneficiary, wallet, bank rail, invoice, website, and ownership evidence before drafting any payment-facing note.

Not ready signals

One or more required evidence fields are missing, uncited, or unresolved: operator_identity, payment_destination, source_links, match_confidence.
The case is past sourceReviewPolicy.nextRecommendedReviewAt without a fresh source re-check.
The user or downstream agent asks for approval, clearance, safety, compliance, suitability, execution, payment, publication, or legal/trading advice.
The requested case uses a new counterparty, payment destination, wallet, claim, filing, macro release, source set, or audience that is not covered by the static sample.

Ready static handoff

A bounded static action note or evidence card with citations, source snapshot, unresolved items, and blocked-upgrade language preserved.
A JSON artifact reference plus canonical citation text that another crawler or agent can retrieve without treating it as a live service.
A human-review handoff when the case remains high-risk, private, legally sensitive, or close to money movement or public distribution.

Case worksheet

caseWorksheet: counterparty_screening_pack_case_worksheet

worksheetType: counterparty_source_query_ledger

Treat this worksheet as complete only when every row preserves source/citation fields, result semantics, safe rewrite, blocked rewrite, and escalation reason.

OFAC source-query row · OFAC Sanctions List Service

Capture the legal name, aliases, identifiers, jurisdiction, query terms, beneficiary or payment destination, retrieval time, and ownership evidence used for the OFAC source query.

Result semantics: Record exact match, partial match, no-hit, unresolved identifier, alias mismatch, jurisdiction mismatch, and match confidence separately.

Unsafe category: sanctions no-hit upgraded into counterparty clearance or payment approval

Safe restatement: the cited OFAC source row records the query basis and match semantics only; it does not approve the counterparty or payment destination.

Do not say the counterparty is safe, compliant, verified, cleared, approved, or that payment can proceed because this row exists.

Trade.gov CSL source-query row · Trade.gov Consolidated Screening List

Capture CSL query terms, legal name, aliases, source categories, country or jurisdiction, source URL, retrieval time, and payment-destination relationship.

Result semantics: Record exact match, partial match, no-hit, unresolved source category, and match confidence without turning no-hit into clearance.

Unsafe category: CSL no-hit upgraded into compliant vendor approval

Safe restatement: the CSL source row is a source-bound observation with named query terms, retrieval time, and unresolved match limits.

Do not say the vendor is compliant, safe, approved, cleared, verified, or ready to proceed from a static CSL row.

SAM.gov and World Bank query row · SAM.gov Exclusions API / World Bank debarred firms

Capture exclusion/debarment query basis, legal identifiers, jurisdiction, procurement relevance, beneficiary/payment destination, source URL, and retrieval time.

Result semantics: Record exact exclusion or debarment match, partial match, no-hit, unresolved identifier, and match confidence for each source separately.

Unsafe category: exclusion/debarment query treated as complete payment clearance

Safe restatement: these source rows describe exclusion/debarment evidence and unresolved identifiers, not payment approval.

Do not say the counterparty is safe, compliant, verified, approved, cleared, or that payment can proceed because no issue was found.

Trading-services warning and aggregator context row · CFTC RED List / OpenSanctions

Capture trading-service relevance, alias and identifier hints, aggregator context, official-source follow-up, jurisdiction, query basis, match semantics, and retrieval time.

Result semantics: Record exact warning match, partial warning match, no-hit, aggregator-only context, unresolved alias, and source-confidence limits.

Unsafe category: public warning or aggregator context upgraded into official clearance

Safe restatement: warning and aggregator rows can explain risk context and alias uncertainty while official sources remain separate.

Do not say the counterparty is safe, compliant, approved, verified, cleared, or suitable because an aggregator row or no-hit exists.

Beneficiary and payment-destination ownership row · Supplier onboarding packet and verified payment channel sample

Capture beneficiary name, wallet or bank destination, invoice or settlement instruction, known-good channel, domain, ownership proof, and mismatch notes.

Result semantics: Record exact ownership match, partial ownership match, no-hit, unresolved ownership, mismatched beneficiary, or changed destination before any payment handoff.

Unsafe category: beneficiary or wallet ownership gap upgraded into proceed/payment approval

Safe restatement: the beneficiary and destination evidence is incomplete, so the payment remains in review and cannot be approved by the static pack.

Do not say the beneficiary is verified, the wallet is safe, the bank rail is approved, or the payment can proceed.

Source manifest handoff

Sample evidence card id: counterparty_screening_pack_sample_evidence_card

Source manifest entries: 8

Official registry sources: 5

Source quality boundary: static_source_manifest_not_live_screening

Canonical citation artifact version: public-material-counterparty-screening-pack-2026-05-25

Source snapshot: 2026-05-25T00:00:00.000Z

This is a static citation handoff for retrieval. It records cited sources, source roles, evidence links, and limitations without turning the pack into live clearance or approval.

Machine summary

Pack: counterparty_screening_pack

Page: https://trading4ai.com/agent-verification/materials/counterparty-screening-pack

Artifact: https://trading4ai.com/reliability/public-materials/counterparty-screening-pack.json

Action type: counterparty_payment_review

Default posture: review

Minimum input fields: operator_identity, payment_destination, source_links, match_confidence

Decision matrix rows: 6

Evidence verification steps: 5

Misuse patterns: 3

Agent use

Open the HTML page first for scope, limitations, source freshness, and scenario fit.
Use the JSON artifact for structured retrieval after the page boundary is understood.
Carry the canonical citation, source snapshot, limitations, and unresolved items into downstream summaries.

Do not use as

live screening
payment approval
compliance clearance
trading or execution advice
proof that a counterparty, wallet, claim, filing, or macro interpretation is safe

Decision matrix labels

OFAC sanctions source row
Trade.gov CSL official source row
SAM.gov exclusions source row
World Bank debarred firms source row
CFTC RED List trading-services row
OpenSanctions aggregator context row

Evidence verification step labels

Official registry and official source verification
Evidence record linkage check
Decision matrix boundary check
Canonical citation and timestamp check
Human escalation and blocked-upgrade check

Misuse pattern labels

No-hit treated as clearance
Aggregator context treated as official clearance
Beneficiary or wallet destination collapsed into counterparty identity

Evidence verification recipe

Pack: counterparty_screening_pack

Default posture: review

Static only: yes

Official registry and official source verification
Verification action: Check OFAC, Trade.gov CSL, SAM.gov exclusions, World Bank debarred firms, CFTC RED List, and any listed aggregator context against the exact entity, alias, jurisdiction, and identifier fields in the source manifest.
Trust boundary: A no-hit, partial match, stale query, or aggregator-only row is not sanctions clearance, safe counterparty approval, compliant payment approval, or permission to proceed.
Failure mode: If identifiers, retrieval time, source category, or match confidence are missing, keep the payment in review and do not call the counterparty safe or approved.
Required citation fields: sourceManifest[].url, sourceManifest[].retrievedAt, sourceManifest[].kind, sampleEvidenceRecords[].id, decisionMatrix[].matrixId
Evidence record linkage check
Verification action: Match each sample evidence record to a sourceManifest evidenceRecordIds entry, then preserve the record status, note, source label, source URL, and retrievedAt value.
Trust boundary: A sample record explains the static example only; it does not prove the current counterparty, claim, payment, wallet, filing, macro release, or subscription is safe.
Failure mode: If a record cannot be linked to its source manifest row, do not reuse it as evidence and keep the final output unresolved.
Required citation fields: sampleEvidenceRecords[].id, sampleEvidenceRecords[].status, sampleEvidenceRecords[].sourceUrl, sampleEvidenceRecords[].retrievedAt, sourceManifest[].evidenceRecordIds
Decision matrix boundary check
Verification action: Read all 6 decision matrix rows and carry their allowedStaticUse, blockedUpgrade, and agentAction fields into any downstream summary.
Trust boundary: Decision matrix rows define allowed static reuse and blocked upgrades; they are not automatic live approval, live screening, compliance sign-off, or execution permission.
Failure mode: If a downstream sentence conflicts with a blockedUpgrade row, block or rewrite the sentence and escalate when money, publication, or user action is involved.
Required citation fields: decisionMatrix[].matrixId, decisionMatrix[].status, decisionMatrix[].allowedStaticUse, decisionMatrix[].blockedUpgrade
Canonical citation and timestamp check
Verification action: Preserve the canonical citation text, artifact version, generatedAt, staticSnapshotAt, sourceSnapshotAt, and all source retrievedAt values when citing this pack.
Trust boundary: A citation proves the static artifact and source snapshot were recorded; it does not prove the facts are current beyond the listed timestamps.
Failure mode: If artifact version, generatedAt, sourceSnapshotAt, or source retrievedAt values are removed, the output is no longer evidence-bound.
Required citation fields: canonicalCitation.recommendedCitationText, artifactProvenance.artifactVersion, artifactProvenance.generatedAt, canonicalCitation.sourceSnapshotAt, sourceManifest[].retrievedAt
Human escalation and blocked-upgrade check
Verification action: Compare the final output with the pack's blockedStatements, sampleReviewOutput.blockedRestatement, escalationTriggers, and actionTaxonomy.stopOrEscalateWhen fields.
Trust boundary: Static public material may explain evidence and limitations, but it must not become live clearance, legal compliance, suitability, safety, guarantee, payment approval, publication approval, or trade advice.
Failure mode: If the output asks a user or agent to move money, publish a financial claim, trust a counterparty, or treat the material as live approval, stop and escalate to human review.
Required citation fields: canonicalCitation.recommendedCitationText, artifactProvenance.artifactVersion, blockedStatements[], sampleReviewOutput.blockedRestatement, escalationTriggers[], actionTaxonomy.stopOrEscalateWhen[]

Cite this pack

Counterparty screening before payment, public-material-counterparty-screening-pack-2026-05-25, generated 2026-05-25T00:00:00.000Z, source snapshot 2026-05-25T00:00:00.000Z, https://trading4ai.com/agent-verification/materials/counterparty-screening-pack

Page: https://trading4ai.com/agent-verification/materials/counterparty-screening-pack

Artifact: https://trading4ai.com/reliability/public-materials/counterparty-screening-pack.json

Source snapshot: 2026-05-25T00:00:00.000Z

Source manifest

Previously verified vendor record (sample)
URL: /agent-verification/materials/counterparty-screening-pack
Kind: sample_page; role: sample_context; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: beneficiary_mismatch, entity_resolution_fields_missing, instruction_channel_change, beneficiary_proof_missing
Supports: Beneficiary name in the payment draft does not match the previously verified vendor record / Entity-resolution evidence is incomplete across legal name, alias, identifier, country, jurisdiction, and partial-match fields / Updated payment instructions arrived from a domain that was not the previously verified vendor domain / No signed bank letter or portal confirmation ties the new beneficiary account to the claimed counterparty
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.
OFAC Sanctions List Service
URL: https://ofac.treasury.gov/sanctions-list-service
Kind: official_registry; role: official_reference; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: ofac_name_search
Supports: OFAC sanctions search returned no exact listed match for the supplied counterparty spelling / This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.
Trade.gov Consolidated Screening List
URL: https://www.trade.gov/consolidated-screening-list
Kind: official_registry; role: official_reference; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: trade_csl_source_required
Supports: Trade.gov Consolidated Screening List (CSL) review remains required for the supplied counterparty / This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.
SAM.gov Exclusions API
URL: https://open.gsa.gov/api/exclusions-api/
Kind: official_registry; role: official_reference; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: sam_exclusions_source_required
Supports: SAM.gov exclusions coverage remains required through the public GSA Exclusions API reference / This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.
World Bank debarred firms
URL: https://www.worldbank.org/en/projects-operations/procurement/debarred-firms
Kind: official_registry; role: official_reference; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: world_bank_debarred_source_required
Supports: World Bank debarred firms review remains required for procurement-style counterparty screening / This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.
CFTC RED List
URL: https://www.cftc.gov/LearnAndProtect/Resources/Check/redlist.htm
Kind: official_registry; role: official_reference; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: cftc_red_list_source_required
Supports: CFTC RED List review remains required when the counterparty is offering trading, investment, or brokerage-like services / This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.
OpenSanctions public reference
URL: https://www.opensanctions.org/
Kind: public_reference; role: primary_warning; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: opensanctions_public_reference
Supports: OpenSanctions can support entity-resolution context, but it is a public aggregator rather than an official clearance source / This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.
FTC cryptocurrency scam guidance
URL: https://consumer.ftc.gov/articles/what-know-about-cryptocurrency-scams
Kind: official_guidance; role: primary_warning; retrieved: 2026-05-25T00:00:00.000Z
Evidence records: ftc_crypto_scam_reference
Supports: FTC cryptocurrency scam guidance remains relevant when the counterparty requests wallet payment or crypto settlement / This is a real high-risk pre-action scenario where static risk review material is more useful than generic trading copy.
Limitations:
- This source entry records what the static sample cites; it does not prove current, complete, or final clearance.
- Preserve retrievedAt and linked evidenceRecordIds when reusing this source in an agent or crawler workflow.

Sample bounded output

Verdict: review

The public-source checks do not clear the counterparty, and the beneficiary mismatch keeps the payment in human review.

Safe restatement: Checked selected public sources and sample records at the retrieval time shown; the evidence remains incomplete across alias, identifier, jurisdiction, and no-hit semantics, so the payment stays in review, is not cleared, and is not approved by this pack.

Blocked restatement: This counterparty is safe and the payment can proceed.

Unresolved items

The new beneficiary is not independently matched to the previously verified supplier identity.
The instruction channel changed shortly before payment and was not confirmed through an official domain or portal.
No document in the sample package ties the bank account owner to the claimed counterparty with sufficient confidence.
Legal name, alias, identifier, country, jurisdiction, and no-hit or partial-match evidence remain incomplete.
Trade.gov CSL, SAM.gov exclusions, World Bank debarred firms, and CFTC RED List checks remain source requirements, not live clearance results.

Required follow-up

Re-confirm beneficiary and bank details through a previously verified channel or supplier portal.
Capture the exact OFAC, Trade.gov CSL, SAM.gov exclusions, World Bank debarment, and CFTC RED List checks with timestamps in the final evidence card when those sources are relevant.
Hold payment release until the beneficiary mismatch is resolved by a human reviewer.

Review boundaries

How this pack should be used in practice

These sections turn the pack into a bounded public review aid: what to check, when to escalate, and which statements must stay inside evidence limits.

Review checklist

Verify the counterparty name, beneficiary, or wallet label against an official source you can cite.
Record legal name, aliases, identifiers, country or jurisdiction, query terms, partial-match status, no-hit status, and source semantics before summarizing a screening result.
Check whether the payment instructions match a previously verified channel, official domain, or documented payee record.
Record which public lists, registries, or warnings were checked and when the check was performed.
State what still remains unverified before any funds move.

Escalation triggers

Payment instructions changed in a private chat, forwarded message, or new email domain.
The beneficiary or wallet is new and cannot be independently matched to the claimed counterparty.
The request relies on urgency, secrecy, guaranteed safety, or informal exceptions to normal review.

Safe to repeat

Checked selected public sources at the stated retrieval time; no clearance decision was established by this pack alone.
The current evidence is incomplete, so the payment should stay in review rather than move forward automatically.
This pack can describe what was checked and what remains unresolved, but it does not certify the counterparty.

Blocked claims

This counterparty is safe.
This payment is compliant and can proceed.
No further review is needed because no risk was found in the public sources checked.

Related public artifacts

Action Preflight page (HTML page)
Action Preflight JSON sample (JSON artifact)
Evidence Cards page (HTML page)
Evidence Cards JSON sample (JSON artifact)

Machine-readable

Static JSON artifact

The JSON artifact is the stable machine-facing handoff surface for this pack. It is static, public, and safe to crawl.

Artifact path: /reliability/public-materials/counterparty-screening-pack.json

Use the HTML page for explanation and the JSON artifact for machine retrieval.

Artifact provenance

schemaVersion: trading4ai-public-reliability-v1

artifactVersion: public-material-counterparty-screening-pack-2026-05-25

generatedAt: 2026-05-25T00:00:00.000Z

staticSnapshotAt: 2026-05-25T00:00:00.000Z

artifactUrl: /reliability/public-materials/counterparty-screening-pack.json

Citation fields: artifactVersion, generatedAt, sampleEvidenceRecords[].retrievedAt, sampleReviewOutput.verdict, sourceRefs

When citing this pack, preserve artifactVersion, generatedAt, sampleEvidenceRecords[].retrievedAt, and sourceRefs together.

Do not turn the pack into payment approval, safety clearance, or compliance sign-off.