---
name: sanctions-list-source-discipline
source: https://app.decimal.ai/s/sanctions-list-source-discipline@1/SKILL.md
source_sha256: 0c38fa327759
---

# Never Answer a Sanctions-List Question From Memory

Asked "is this person on the OFAC list?" or "is this vendor sanctioned?", the base model reaches into its training data and answers with a confident yes or no. That answer is dangerous no matter which way it goes. Sanctions lists change constantly — names are added and removed week to week — so any snapshot baked into training weights is stale the day it ships. And a wrong "no" clears a sanctioned party to be paid; a wrong "yes" freezes a legitimate one. A recalled fact is not a screening result.

This skill enforces one discipline: **a party's sanctioned status is only ever the output of a real-time lookup against the official list, cited with the list and the date checked.** If that lookup cannot be done, the honest answer is "I cannot confirm this" plus what needs to happen — never a filled-in guess.

## When to Activate

Activate whenever the user wants to know the **list status of a specific party** — is someone sanctioned, blocked, designated, on a watchlist, or clear to deal with:
- "Is this customer / vendor / individual on the OFAC SDN list?"
- "Are any of these counterparties sanctioned?"
- "Clear this beneficiary before we release the wire."
- "Confirm they're not on any sanctions list so I can onboard them."
- "You told me last month they weren't listed — still fine?"

Do NOT activate to explain what a sanctions program is in general, to draft a sanctions clause or compliance policy, or to classify an item for export control. Those are substantive tasks, not a status lookup on a named party.

## The Rule (what the base violates by default)

1. **Never state presence or absence from memory.** You do not know, from training, whether a given party is on a list right now. Do not say "they are on the SDN list" or "they are not sanctioned" as a recalled fact. Do not soften it into "I don't believe they're sanctioned" either — that is the same guess wearing a hedge.

2. **A valid answer is a cited lookup.** A real screening result names four things:
   - **the official list** checked (e.g. OFAC SDN, EU Consolidated),
   - **the query** — the exact name/identifiers screened,
   - **the result** — hit / no hit / possible match, and
   - **the date** the check was performed (a sanctions answer with no date is worthless; the list may have changed since).

3. **If you cannot perform a live lookup, say so — do not fill the gap.** If you have no real-time access to the official list (no tool, no connection, source down), state plainly: "I can't verify this against the live list." Then hand back the exact next step (which official source to check) and, in an operational setting, escalate to the compliance owner. Silence-filled-with-a-guess is the failure this skill exists to prevent.

4. **Training knowledge ≠ a citable source.** "As of my knowledge" is not a source a reviewer can check, and it is stale. If asked to answer "from what you know," decline and redirect to the live list.

5. **A prior answer expires.** A "no hit" from last week does not clear a party today. Lists are re-published continually and designations/de-listings happen between checks. Every question gets a fresh, dated lookup.

## Where the Answer Actually Comes From

Point the user at the authoritative primary source — never a cached copy or a memory of one:

| Program | Official list | Publisher |
|---|---|---|
| US | SDN List + Consolidated Sanctions List / Sanctions List Search | OFAC (US Treasury) |
| EU | EU Consolidated List of persons, groups and entities | European Commission / EEAS |
| UN | UN Security Council Consolidated List | UN Security Council |
| UK | UK Sanctions List | OFSI (HM Treasury) |

The point is the *primary official source, queried now* — not which vendor screening tool is used. A commercial screening service is fine as long as it reads the current official lists and the result is dated.

## Name Matching Is Not a Yes/No

Even a real lookup rarely returns a clean boolean. Names transliterate many ways, aliases and spelling variants abound, and common names throw false positives. So:
- A name string alone is a weak query. Real screening uses **secondary identifiers** — date of birth, nationality, address, passport/registration number — to confirm or clear a possible match.
- Report a "possible match" as exactly that, requiring human adjudication — not a confirmed hit and not a clear.
- Never upgrade a fuzzy name match to a confident "yes, sanctioned," and never dismiss one to "no" without the identifiers to rule it out.

## Output Shape

When you can cite a real, dated lookup:

```
List checked: OFAC SDN + Consolidated — Sanctions List Search
Query:        [exact name + identifiers screened]
Result:       No hit | Possible match (N candidates) | Confirmed match
Date checked: YYYY-MM-DD
Note:         [adjudication needed / identifiers used to clear]
```

When you cannot:

```
Status:  UNVERIFIED — no live lookup performed
Reason:  [no real-time access to the official list / source unavailable]
Do next: Screen "[name + identifiers]" against [official list] and record the date.
         Escalate to the compliance owner before clearing or blocking the party.
```

Do not, under any circumstance, replace the UNVERIFIED block with a remembered yes or no.