Question 1

A payor just flagged. Can we still process the payment?

Accepted Answer

Hold the payment until the match is resolved. Processing a payment while a match is unresolved creates an unfavorable posture in any subsequent OFAC enforcement action — even if the match later clears. SecurePoint's payor record automatically moves into "hold" status when a potential match surfaces.

Question 2

How do we know whether it is actually the same person?

Accepted Answer

Compare date of birth, nationality, country context, middle names, and payment metadata against the matched SDN record. SecurePoint surfaces the comparable fields side by side inside the case review. Decision templates enforce a written rationale before the case can close.

Question 3

What if the match is ambiguous?

Accepted Answer

Escalate instead of guessing. Ambiguous matches route to a higher-privilege reviewer — typically a compliance lead or general counsel — and stay in hold status until a documented decision is made. The audit trail captures the ambiguity and the escalation path, which is exactly what a regulator or auditor wants to see.

Question 4

What if it IS the same person?

Accepted Answer

Do not unilaterally reject. On Plus and Enterprise, the licensing engine immediately surfaces the "Explore Licensing Options" panel. A General License may already authorize the transaction — if so, you proceed with documentation. If not, a Specific License application can be drafted and submitted to OFAC. A preserved relationship depends on exploring the licensing path before the rejection.

Question 5

What do we hand to counsel?

Accepted Answer

The evidence pack. It includes the screening result, the matched SDN record, the reviewer's comparison and rationale, the licensing assessment output (if applicable), the Specific License draft (if applicable), and the immutable timestamps. Counsel reviews and signs off.

Question 6

What if we already processed the payment before the flag?

Accepted Answer

Retroactive licensing alerts on Plus and Enterprise catch a case where a previously cleared payor is newly designated under a different sanctions program. The alert surfaces before the next billing cycle. If a payment has already posted, counsel guidance typically involves a voluntary self-disclosure to OFAC with the evidence pack attached — which is exactly what the pack is built to support.

A tuition payor just flagged — this is the workflow

The first 24 hours shape the audit posture

What to do, in order

Hold the payment

Open the match review

Compare identifiers

Decide — with documentation

Explore the licensing path (Plus+)

Export the evidence pack

A confirmed match is not automatically a lost relationship

What to read next

Sample Evidence Pack

OFAC Licensing

How to Clear a Screening Alert

Continuous Monitoring

Audit & Recordkeeping

Education Launch

For Compliance Leads

For Business Offices

Education White Paper

Flagged-payor workflow — FAQ

Don't improvise the flagged-payor response