Table of Contents
Maker checker sanctions screening splits one screening decision between two people. One person reviews the alert and proposes an outcome. A second person checks that work and approves or rejects it. The goal is simple. No single person can clear a possible sanctions match on their own.
This control is also called the four-eyes principle. It sits at the heart of a strong denied party screening program. This guide explains how it works, who does what, where teams get it wrong, and how to make it hold up under audit.
What maker checker means in screening
Maker checker is a segregation of duties control. It takes one task and forces two sets of eyes onto it. In sanctions screening the task is the alert decision. Your system compares a name against a watchlist and flags a possible hit. Someone has to decide if the hit is real.
The maker does the first review. They look at the alert, gather the facts, and propose a call. The checker looks at the same alert with fresh eyes. They confirm the work or send it back. Only after the checker signs off does the decision take effect. The two roles must be different people.
Screening alerts are mostly false positives. A common name can match a listed party by accident. But some alerts are real. If one rushed analyst can close every alert alone, one mistake can let a blocked party through. A second reviewer catches that.
Why the control matters
Sanctions rules are strict liability. You can be penalized even when the breach was an honest error. Regulators expect controls that reduce single points of failure. Maker checker is one of the clearest ways to show that.
It gives you three things at once.
- Error reduction. A second reviewer catches wrong calls before they close.
- Fraud deterrence. Waving through a bad party now needs two people to agree. Collusion is harder to hide.
- Accountability. Every alert shows who reviewed it, who approved it, and when.
That last point matters for audits. When an examiner asks how you cleared a specific alert, you can point to two names and two timestamps. That is far stronger than one person’s word.
The workflow step by step
A clean maker checker flow has four stages. Each stage is logged.
1. Alert generation
Your screening tool matches a name or entity against a watchlist and raises an alert. The party is held. Nothing ships or onboards until the alert is resolved.
2. Maker review
The maker investigates. They compare the alert against the source list entry. They check name, address, date of birth, country, and any known aliases. They record their reasoning and propose an outcome. The usual outcomes are true match, false positive, or escalate.
3. Checker review
The checker reviews the same alert independently. They do not just rubber stamp the maker’s note. They test the logic. If they agree, they approve. If they disagree or the notes are thin, they reject and send it back with a reason.
4. Decision and logging
Once approved, the outcome takes effect. A false positive releases the party. A true match blocks it and triggers reporting steps. The system writes a tamper-proof record of the whole chain. See our guide on how to process denied party screenings for the review detail.
Maker and checker roles compared
| Aspect | Maker | Checker |
|---|---|---|
| Main job | Investigate the alert and propose an outcome | Review the work and approve or reject it |
| Seniority | Often a first-line analyst | A more experienced compliance officer |
| Records | Notes, evidence, proposed decision | Confirmation or reason for rejection |
| Authority | Cannot finalize alone | Makes the outcome effective |
Escalation for high-risk alerts
Two eyes are not always enough. Some alerts are too serious for a maker and checker to close between them. Build a third tier for these cases.
Escalate to senior compliance or the sanctions officer when you see any of the following.
- A likely true match against a sanctions list.
- An entity that may be caught by the 50 percent rule through ownership.
- Signs of deliberate evasion, such as changed names or hidden routing.
- Any case where the maker and checker cannot agree.
Escalation should be a defined path, not an ad hoc call. Write down who receives escalations and how fast they must respond. Watch for the warning signs in our guide to red flags of sanctions evasion.
Matching against the right lists
Maker checker only works if the underlying lists are current. Both reviewers should compare the alert against the actual source entry, not a stale copy. In the US the core sanctions list is the OFAC Specially Designated Nationals list, published by the US Treasury Office of Foreign Assets Control.
Most programs also screen against export lists like the BIS Entity List and the Denied Persons List. The maker confirms which list the hit came from. The checker confirms that the match still holds against the live entry. For the SDN detail see our note on the OFAC SDN list.
Common mistakes to avoid
The control fails quietly when teams cut corners. Watch for these traps.
- Rubber stamping. The checker approves without a real second look. This defeats the whole point.
- Role overlap. The same person acts as maker and checker under a staff shortage. System permissions must block this.
- Thin notes. The maker records a decision with no reasoning. An auditor cannot follow the logic later.
- Alert backlogs. Reviews pile up and get closed in a rush. Pressure leads to weak checks.
- Stale lists. Reviewers work from an old watchlist and miss a new designation.
When you decide between people and software, keep the second review real. Our comparison of automated versus manual screening explains where each fits. Technology should support human judgment, not replace it.
Making it audit-ready
An examiner will test whether the control is real or just on paper. Give them a clean trail. Every alert should show the maker, the checker, both decisions, and both timestamps. This is your audit trail.
Keep these records for the full retention period. Most exporters keep screening records for at least five years. See our guide to record keeping for denied party screening. Pair the workflow with the wider steps in our denied party best practices.
Test the control on a sample of closed alerts. Pull a batch and confirm two different people signed each one. Confirm the false positives were resolved with real evidence, using steps like those in how to resolve a false positive. If any alert shows one name doing both jobs, you have a gap to fix.
Frequently Asked Questions
Is maker checker the same as the four-eyes principle?
Yes, in practice. Both mean two people must be involved in one decision. Four-eyes describes the outcome. Maker checker names the two roles that produce it.
Can one person be maker and checker on different alerts?
Yes. A person can be a maker on some alerts and a checker on others. The rule is that they cannot be both on the same alert. System permissions should enforce that split.
Does a small team have to use maker checker?
Small teams still need a second reviewer for sanctions hits. If you have very few staff, you can name a manager or an outside reviewer as checker. Do not let one person close alerts alone.
What should the checker actually verify?
The checker confirms the match logic, the source list entry, and the evidence behind the maker’s call. They make sure the reasoning is sound and the notes are complete before they approve.
Key Takeaways
Maker checker sanctions screening puts two people on every alert decision. The maker investigates and proposes. The checker reviews and approves. No one clears a possible match alone. Add an escalation tier for true matches and evasion signs. Keep the lists current and log every step. Done well, this control cuts errors, deters fraud, and stands up to audit. If you want help building it into your program, contact us.