MTD-STD-03 · Sanctions Screening Standard (v5.3)

Identity, integrity & provenance

Document id

mtd-std-03

sha256 (the integrity anchor citations pin to)

e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5

Covers the extracted text, 1745 characters of it.

Added by

Demo User

Added at

2026-10-04 18:51 UTC

Source

register_document

Retain until

2032-10-04

Document control — provenance carried to the assessment stages as evidence metadata

Reference

MTD-STD-03

Version

5.3

Owner

Head of Financial Crime

Approved by

Risk and Compliance Committee

Approved

22 January 2026

Classification

Internal

Next review due

January 2027

Allocated to assessments

Where this document's content was filed at triage — 1 section. A section can be allocated to more than one assessment. Change it with Triage and allocate, in the actions at the top of this page.

4. Transfer screening

4.1 Outbound transfers of funds and crypto-assets are screened before release, and inbound transfers before funds or assets are made available.

4.2 Screening runs against the parties to the transfer as they appear in the transfer message: the name, address and identifier fields as submitted for screening.

4.3 Potential matches are held pending review; confirmed matches are blocked or frozen and escalated in accordance with §5.

4.4 Matching uses fuzzy logic calibrated to balance detection against alert volume; thresholds and their calibration evidence are governed under §6.

EU 2023/1113 — Mittenda Limited

Mittenda Limited owns and performs the screening of outbound and inbound transfers of funds and crypto-assets described here, as a PSP/IPSP/CASP/ICASP. The section sets the operating standard the unit applies to transfer messages, so it is evidence for the EU 2023/1113 assessment of that unit.

Not allocated

Text no triage section covers — 5 passages. Often this is the title, document-control metadata or sign-off; if any of it belongs to an assessment, file it with Triage and allocate, in the actions at the top of this page.

# Mittenda Limited · Sanctions Screening Standard (v

) · specimen excerpt > **Synthetic specimen.** Mittenda Limited is a fictional firm. This document is invented, > derived from scenarios seen in practice, and contains deliberate deficiencies for > demonstration. It is not a template and must not be adopted. **Document control:**

. | Version | Date | Change | |---|---|---| |

| January 2026 | Fuzzy-match thresholds recalibrated | | 5.2.1 | July 2025 | Minor corrections; formatting | | 5.2 | April 2025 | Crypto-asset transfer screening in scope | | 5.1 | September 2024 | List-management remediation following internal audit review | *[Earlier versions omitted]* **Contents** 1. Purpose 2. Lists and list management 3. Customer screening 4. **Transfer screening** 5. Match handling 6. Governance Appendix A: Lists in scope *Sections in bold are excerpted below.* *[Sections 1 to 3 omitted]* ## 4. Transfer screening

*[Sections 5 onward and Appendix A omitted]*

Document text

1745 chars

Mittenda Limited · Sanctions Screening Standard (v5.3) · specimen excerpt

Synthetic specimen. Mittenda Limited is a fictional firm. This document is invented, derived from scenarios seen in practice, and contains deliberate deficiencies for demonstration. It is not a template and must not be adopted.

Document control: MTD-STD-03 · owner: Head of Financial Crime · approved: Risk and Compliance Committee, 22 January 2026 · classification: Internal · next review due: January 2027.

Version	Date	Change
5.3	January 2026	Fuzzy-match thresholds recalibrated
5.2.1	July 2025	Minor corrections; formatting
5.2	April 2025	Crypto-asset transfer screening in scope
5.1	September 2024	List-management remediation following internal audit review

[Earlier versions omitted]

Contents

Purpose
Lists and list management
Customer screening
Transfer screening
Match handling
Governance

Appendix A: Lists in scope

Sections in bold are excerpted below.

[Sections 1 to 3 omitted]

4. Transfer screening

4.1 Outbound transfers of funds and crypto-assets are screened before release, and inbound transfers before funds or assets are made available.

4.2 Screening runs against the parties to the transfer as they appear in the transfer message: the name, address and identifier fields as submitted for screening.

4.3 Potential matches are held pending review; confirmed matches are blocked or frozen and escalated in accordance with §5.

4.4 Matching uses fuzzy logic calibrated to balance detection against alert volume; thresholds and their calibration evidence are governed under §6.

[Sections 5 onward and Appendix A omitted]

What it evidences

Risks (1):Restrictive-measures policies, procedures and controls not in place

Controls (15):In-flight pre-dispatch and pre-availability sanctions screening gate Restrictive-measures framework policy and training Confirmed sanctions-hit freeze execution and notification workflow Crypto counterparty attribution feed for sanctions screening Periodic review of meaningless-terms list Coherent-designation false-positive guard Automated inbound admissibility detection at intake Pipeline ordering enforcing pre-processing admissibility detection Manual-review workflow definition and ownership Intake-timed placement of missing-information detection Pre-dispatch beneficiary-identity reconciliation against counterparty reference Originator-name format preservation check

12 of 15 shown

Obligations (8):Internal controls for implementing restrictive measures Reject the transfer or return the crypto-assets to the originator Pay-out in cash or anonymous electronic money Reject the transfer or return the transiting crypto-assets Request missing originator and beneficiary information before crediting Sanctions-related geography as monitoring risk factor Endpoints linked to suspicious activity as risk factor Verify beneficiary information before making crypto-assets available

Cited by (27):

Cited by	Suggestion	Version	When
Mittenda Limited	Coverage Not evidenced — Pre-crediting beneficiary-verification gate sg-0381	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Outbound beneficiary-information placeholder detector sg-0371	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Random-sample effectiveness testing of admissibility detection sg-0325	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Originator-name format preservation check sg-0324	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Pre-dispatch beneficiary-identity reconciliation against counterparty reference sg-0322	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Intake-timed placement of missing-information detection sg-0315	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Pipeline ordering enforcing pre-processing admissibility detection sg-0312	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Manual-review workflow definition and ownership sg-0314	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Partial — Automated inbound admissibility detection at intake sg-0304	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13
Mittenda Limited	Coverage Not evidenced — Coherent-designation false-positive guard sg-0303	current — v1`sha256 e2785f338bcb2defb7ab575f378d33e674dda9c2e5706cd7b4581c2593b446b5`	2026-10-04 20:13

10 of 27 shown

Assistant findings

27 grounded in this document

What the assistant surfaced from this document — accept or reject them on the findings and coverage page.

Finding	Value	Confidence	Status
Head of Financial Crime (MLRO) sg-0004	Head of Financial Crime (MLRO)	High	Accepted
Risk and Compliance Committee sg-0006	Risk and Compliance Committee (group)	High	Accepted
Internal controls for implementing restrictive measures sg-0022	Partial	Medium	Accepted
In-flight pre-dispatch and pre-availability sanctions screening gate sg-0042	Partial	Medium	Accepted
Restrictive-measures framework policy and training sg-0060	Partial	Medium	Accepted
Confirmed sanctions-hit freeze execution and notification workflow sg-0071	Not evidenced	Medium	Accepted
Crypto counterparty attribution feed for sanctions screening sg-0072	Not evidenced	Medium	Accepted
Restrictive-measures policies, procedures and controls not in place sg-0077	marks risk live	High	Accepted
Restrictive-measures policies, procedures and controls not in place sg-0080	new control · nature not proposed	Medium	Accepted
Reject the transfer or return the crypto-assets to the originator sg-0114	Not evidenced	Medium	Accepted

10 of 27 shown

Audit timeline

Every event on this document (43)

When (UTC)	Actor	What	Change
2026-10-06 13:38:07	Demo User	Document viewed	"MTD-STD-03 · Sanctions Screening Standard (v5.3)" opened on the register detail.
2026-10-06 13:38:06	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:10:58	Demo User	Document viewed	"MTD-STD-03 · Sanctions Screening Standard (v5.3)" opened on the register detail.
2026-10-06 10:10:58	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 10:05:30	Demo User	Document viewed	"MTD-STD-03 · Sanctions Screening Standard (v5.3)" opened on the register detail.
2026-10-06 10:05:30	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-06 08:53:39	Demo User	Document viewed	"MTD-STD-03 · Sanctions Screening Standard (v5.3)" opened on the register detail.
2026-10-06 08:53:38	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-05 10:22:10	Demo User	Document viewed	"MTD-STD-03 · Sanctions Screening Standard (v5.3)" opened on the register detail.
2026-10-05 10:22:10	Demo User	Document content_accessed	Content read by a Restricted clearance (document Internal).
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
2026-10-04 20:13:07	Demo User	Document cited	Cited by an accepted suggestion.
15 of 43 shown