Why AML screening may not return the result you expected

AML screening in BNDRY checks a person or company against data from our screening provider. When you expect a match and none appears, the cause depends on the type of result. Sanctions and politically exposed person (PEP) matches follow defined criteria. Adverse media, regulatory exposure and other profiles of interest don't. They depend on the provider's judgement, and there is no universal standard for what qualifies. This article covers the most common reasons for an expected result not appearing.

Sanctions and PEP results

These results follow defined criteria, so a missing match usually means the person or company doesn't meet them.

• The person isn't named on a sanctions list. A sanctions match means the person or company is named on a sanctions list. Living in, or coming from, a sanctioned country isn't a match. A newly published listing can also take a short time to reach our provider's data.
• The position isn't one that's classified as a PEP. A PEP match depends on the position a person holds, not on whether they hold public office. Positions are classified by seniority, and the lowest level of local government classified as a PEP is mayor. A councillor holds public office but isn't a mayor, so they won't return a PEP match.
• The person is only distantly related to a PEP. Family connections are matched for the immediate family and the partner of a PEP. A more distant relative, such as a cousin, won't return a PEP match on the strength of the relationship alone. Business partners and other close associates are linked only where the relationship is publicly known.
• The company isn't state owned. A company is linked to the state only where the state holds a significant ownership stake or is represented on the board. A company with a minor government connection won't return a match.

Adverse media and other profiles of interest

A profile of interest is a person or company the provider considers relevant to risk beyond a sanctions or PEP match. There's no hard rule for what qualifies, and parameters differ between providers. Providers treat their parameters as proprietary and don't publish them, so we can't share them with you. A result from another screening tool or a web search may not appear in ours, and the reverse is also true.

• The person left their position some time ago. PEP status follows the position. Someone who held a PEP-classified role but has since left it may still be returned for a period, but there's no fixed cut-off. The longer it has been since they left, the less likely a result becomes. A person who left several years ago may no longer return a result.
• The allegations weren't substantiated. Bad press isn't the same as adverse media. Coverage of an allegation that was never substantiated, or that ended with the person being cleared, may not meet the threshold, however prominent the coverage was.
• The source can't be verified or isn't used. Our provider relies on reputable published sources that it can read and verify. When the only coverage sits behind a paywall, the provider may not be able to substantiate it, so it may not be returned. Social media posts, forums and blogs are generally not used either. A web search may still show the coverage.
• The reporting falls outside the provider's parameters. The provider sets its own parameters for what counts. These cover the type of conduct, such as terrorism, organised crime, modern slavery, financial crime and fraud, bribery and corruption, or cybercrime. They also cover how recent the reporting is and, for some types of financial crime, the value involved. Older reporting, conduct that doesn't fit a covered type, or an amount below the threshold may not return a match, even when the reporting is accurate.
• The regulatory action isn't on an official list. Regulatory exposure results come from official lists published by financial regulators and law enforcement bodies. Action that hasn't been published on one of those lists may not return a match. Coverage differs between jurisdictions, and recent actions can take time to appear.

Widening your checks with Identity Research

Identity Research is an automation that supplements AML screening for individuals. It runs a broad AI-powered web search that isn't bound by the provider's parameters, so it can find reporting that AML screening excludes, such as older coverage or conduct outside the provider's covered types.

Because it casts a wider net, its results can be less reliable. Treat them as leads to review rather than confirmed matches. Used alongside AML screening, the two give you a fuller picture, and you decide which findings matter based on your own risk appetite.

No screening service is foolproof

Every screening provider decides what to include, and that's what keeps its matches focused and dependable. The trade-off is breadth. A clear result means nothing in our provider's data met its criteria when the screen ran. It doesn't mean nothing is publicly known about the person.

You know your customer best. Neither AML screening nor Identity Research is the final word. Both are guides to support your own assessment, not a safe harbour. What counts as risky depends on your business, and coverage that matters to one customer may be irrelevant to another. If you hold information that points the other way, such as local knowledge or a news article, record it and apply your own judgement under your AML/CTF program.

If you think a result is missing

Contact our support team and include the name of the individual or company, the date it was screened, and what you expected to find, such as the position held or a link to the article. We'll check it against the reasons above and let you know what we find.