Corpus v4· 4,812 policies· 28 jurisdictions· Last revision 22 Aug 2026: Affiliates Rule reimposed

Arqis/Solutions/Banks & trade finance desks

The wire cleared. Did the screening?

Sanctions screening happens at onboarding, once. The correspondent chain behind a trade finance facility keeps moving after that: nested banks change, beneficial owners change, a shell entity two hops back gets designated. Arqis determines what OFAC, BIS and the Bulk Data Rule require for a relationship, and keeps that answer live for as long as the facility runs.

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TA-2026-1042
Decided 2 Aug 2026 · corpus v1
Monitored
Conditional

Issue a letter of credit for a trade finance facility routed through a nested correspondent bank.

Correspondent chain screening31 CFR 501
Beneficial ownership trace31 CFR 1010
Underlying goods classification15 CFR 748
Bulk data transfer reviewEO 14117
Reopened by corpus v4
  • Verdict Conditional → Restricted
  • Correspondent status Cleared → Designated
  • A shell entity two hops back in the correspondent chain was added to the SDN list

The exposure

One facility, six ways to be exposed.

A single trade finance deal can carry all of these at once: the payment chain, the goods behind it, and every correspondent in between.

Screening31 CFR 501SWIFT message and beneficiary screening against the SDN and sectoral lists
Correspondent risk31 CFR 501Nested correspondent exposure, several hops removed from the direct relationship
Trade finance15 CFR 748Underlying goods classification for the facility being financed
Beneficial ownership31 CFR 1010Customer due diligence and ultimate beneficial owner trace
Bulk dataEO 14117 · 28 CFR 202Bulk transaction and account data shared with a country of concern
DisclosureReg S-K · Item 103Exposure disclosure for material correspondent relationships

Continuous monitoring

A correspondent chain moves faster than the file.

A relationship is underwritten once, at onboarding. The chain behind it, and the owners behind that, keep changing for as long as it runs.

First

The rule changes

An entity is designated mid-quarter, a corridor is added to enhanced due diligence, a general licence expires. Every correspondent relationship that cited the affected list reopens for review.

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Second

The chain changes

A correspondent adds a new nested relationship, a beneficial owner changes, a shell company appears two hops back. The chain your screening depends on becomes a monitored control, not a one-time file.

Verify

We don't decide who should get a correspondent relationship.

Arqis determines what each applicable regime requires for the chain in front of you. A US issuing bank, a European confirming bank and the underlying trade counterparties can all rely on the same determination.

Decide

Cited, hop by hop

Every test on a correspondent chain names the rule it applied, the list it checked, and the effective date. The reasoning is exposed rather than asserted.

Verify

Correspondent chains become monitored controls

Nested relationships and beneficial ownership are watched continuously, not re-underwritten once a year.

Escalate

Arqis computes, counsel judges

A contested designation or a disputed beneficial owner goes to your own counsel, carrying the full trace, so they start from our work rather than from zero.

Who it's for

Built for the teams who issue the facility.

Arqis sits wherever a correspondent relationship has to be defended later, not just cleared at onboarding.

Trade finance & correspondent banking

Know the chain before you issue

Screen a facility and its correspondent chain against every applicable regime before the letter of credit is issued, not after a wire is flagged.

Sanctions & compliance officers

One file per relationship, not per audit

Every screening decision cited to the rule that produced it, consolidated into a record that stays current between exams.

Legal & regulatory affairs

Defensible before the exam

A correspondent file with a continuous evidence trail is what examiners credit, not a KYC binder that was accurate at onboarding.

Board & risk committee

See the exposure, not just the volume

A nested correspondent flagged mid-quarter is a materially different report than a clean annual review.

Working session

Bring us one correspondent relationship you're unsure about.

Ninety minutes. We run it against every applicable regime on your own correspondent chain and show you the trace. No slides.

Enter your name
Enter a valid work email
Enter your organisation
Tell us roughly what the transaction involves

We reply within one business day. Or email team@arqis.ai directly.

See a determination