What is point-in-time evidence?
An auditor asks one question about a relationship you approved two years ago: what did you know at the time. Point-in-time evidence answers it, reproducing the screening result as it stood on the date it ran, with the same list versions, candidates and disposition.
Sanctions lists change constantly, so a screening result only means something with its date attached. If a system re-runs a stored search against current data, the record can no longer show what the analyst saw or why the decision was reasonable when it was taken. A live re-query answers a different question from the one being asked, and it answers it in a way that quietly rewrites your history.
What this workflow covers
SCOPE- Freeze the inputs, the list versions, every candidate and the disposition at the moment of screening, and export them in a durable format.
- A counterparty screened in March with no match and designated in July still shows no match in the March record. That is correct history, not a gap.
- Editing an old record to reflect a later designation or delisting destroys its evidential value, however well intentioned the edit.
- Every screening here is stored as a snapshot and exported as a PDF that reproduces the result as it stood on the screening date, never recalculated when lists change.
- The snapshot records what the checked sources said on a stated date. It is not a statement that the counterparty was risk-free.
Compliance glossary
TERMS- Snapshot
- A stored copy of a screening result including its inputs, sources, candidates and disposition, fixed at the time of the check.
- List version
- The dated publication of a sanctions list file used for a specific check; recording it is what makes the result reproducible.
Authoritative references
SOURCES- 01A Framework for OFAC Compliance Commitments
U.S. Department of the Treasury — OFAC
- 02The FATF Recommendations — Recommendation 11 (Record keeping)
Financial Action Task Force
- 03Regulation (EU) 2024/1624 — record retention
EUR-Lex, Official Journal of the European Union
Frequently asked questions
Q&A- Why can we not just re-run the search?
- Because the lists have moved since. Without a frozen record you cannot show which list version produced the result, which candidates were reviewed, or why the decision was reasonable on the day. A re-run tells you about today, which nobody is asking about.
- How long do we keep screening evidence?
- AML rules commonly require records for five years after the end of the business relationship or the transaction, with national variations and extensions. Follow the applicable national rule and your own retention policy rather than a single remembered number.
- Is a PDF enough for an audit?
- It is, if it carries the inputs, the sources and list versions checked, the candidates returned, the disposition with its reasoning, and the date and time. A PDF showing a result and a green tick evidences nothing.