Synapse screens users for sanctions & screenings list matches.
When are users screened?
Users are screened after they submit their initial KYC. Users are also screened periodically against updated screenings lists after their initial screening.
What happens when there is a potential screenings list match?
If a user comes up as a potential screenings list match, they will be flagged for manual review by our team upon the creation of their first transaction. When this happens, you will receive a transaction code via webhook indicating that the transaction was queued for further investigation. No further action is required at this point. Our team will review the user to determine whether it was a false positive or a valid screenings list match.
- If the match is a false positive, we will remove the flag and unqueue the transaction without disruption of service.
- If the match is a true match, we will lock the users account (their user 'permission' would be marked as 'LOCKED'). At that time we will also cancel the transaction and send a transaction code via webhook to update you on the reason for canceling the transaction (ex: C48: Sender on screenings list).
- If it is unclear whether the match is a false positive, we will ask for additional identification from the user (typically a US Government issued Photo ID). At that time we will cancel the transaction and send a transaction code via webhook to update you on what is needed to remove the flag (ex: Q03-B: More information needed on receiver: supply Drivers License). After the user supplies the requested information and creates a new transaction, they will go through the same process of manual review to confirm that the updated information is sufficient to determine whether the match is a false positive or a true match.
How do I know if a user is on a screenings list before the first transaction?
Manual review is triggered upon the creation of the first transaction. However, if your team wants to be proactive, you can GET user with full_dehydrate=yes (note that this must be an enabled field on your contract). When you do this, you can check the `flag` key or cycle through the screenings results to see the possible matches. Keep in mind, even if a user is marked as a match, it is sometimes only a false positive. Because of this, you don't need to take action until additional information is requested by our team.
Do I need to file a Suspicious Activity Report (SAR) for a screenings match?
Unfortunately we cannot make that assessment for you. We are obligated to file our own SARs, but your platform will need to determine whether you need to file a SARs for specific scenarios.
If you need additional information about how to handle screenings list matches, please reach out to firstname.lastname@example.org.