Sanctions screening manual fallback activation gate¶

Canonical pattern(s): Contingency plan activation gate Source Markdown: instances/compliance/sanctions-screening-manual-fallback-activation-gate.md

Linked pattern(s)¶

contingency-plan-activation-gate

Domain¶

Compliance.

Scenario summary¶

After a material sanctions-screening outage is declared, compliance leadership has already identified the bounded fallback path and the accountable approval owner: a manual screening contingency for a defined set of payment corridors and protected release holds. Upstream truth-restoration and authority-routing work has already established the trusted outage scope, active payment holds, and decision lane. The planning workflow now has to prepare one activation-ready packet showing reviewer coverage by shift, queue partitioning, legal-notice constraints, protected-channel rules, and the prerequisite controls needed before the manual fallback can be approved. It should preserve explicit holds for any uncovered review cell, unresolved legal hold, or missing queue-control segregation, and stop at the approval gate rather than releasing payments, determining regulator posture, or launching manual screening operations.

flowchart TD A["Declared outage scope, active payment holds, and fallback lane received"] --> B{"Trusted outage references, hold state, and approval lane still match accepted sources?"} B -->|"No"| H["Escalate bounded mismatch for authority-routing conflict or missing authoritative input"] B -->|"Yes"| C{"Reviewer shift coverage, queue partitioning, and protected-channel rules complete for scoped corridors?"} C -->|"No"| G["Keep the packet on hold with explicit uncovered review cells or queue-control gaps"] C -->|"Yes"| D{"Legal-notice constraints, release holds, and prerequisite controls fully represented?"} D -->|"No"| G D -->|"Yes"| E["Assemble the activation-ready packet, readiness ledger, and hold register"] E --> F{"Named compliance approval owner approves the manual fallback packet?"} F -->|"No"| G F -->|"Yes"| I["Record the approved packet and stop at the activation gate without releasing payments or launching manual screening"]

Target systems / source systems¶

Compliance continuity playbooks and outage workspace with the declared fallback scope, protected release boundaries, and prior gate packets
Trusted outage-state, payment-hold, queue-segmentation, and reviewer-coverage systems already accepted as authoritative inputs for fallback preparation
Legal-hold records, delegate rosters, calendars, and staffing plans for sanctions reviewers, queue supervisors, compliance leadership, and legal responders
Approval-routing and audit systems that capture packet versions, hold state, and human sign-off before any manual screening contingency may start
Restricted communications tooling for regulator-response and internal-notice checkpoints that remain downstream of the planning gate

Why this instance matters¶

This grounds the pattern in compliance where the hard problem is preparing a governed activation packet for a sensitive fallback path without blurring into authority recommendation, truth verification, or payment action. It stays planning-centered because the output is a readiness packet with explicit holds and staffing commitments, not a release decision or manual-screening execution record. The instance shows how contingency planning can remain useful and bounded even in a regulator-sensitive outage.

Likely architecture choices¶

flowchart LR subgraph sources["Target systems / source systems"] playbooks["Compliance continuity playbooks and outage workspace"] authority["Trusted outage-state, payment-hold, queue-segmentation, and reviewer-coverage systems"] staffing["Legal-hold records, delegate rosters, calendars, and staffing plans"] end subgraph gate["Sanctions screening manual fallback activation gate"] planner["Activation packet preparation"] ledger[("Readiness ledger")] holds[("Hold register")] packet["Activation-ready packet"] end approver["Compliance leadership approval owner"] audit["Approval-routing and audit systems"] restricted["Restricted communications tooling for regulator-response and internal-notice checkpoints"] playbooks -->|"Provides declared fallback scope and prior gate packets"| planner authority -->|"Provides trusted outage, hold, queue, and coverage inputs"| planner staffing -->|"Provides legal holds, delegates, and staffing commitments"| planner planner -->|"Updates current readiness state"| ledger planner -->|"Keeps explicit blockers visible"| holds planner -->|"Assembles approval packet"| packet packet -->|"Sends packet for human review"| approver packet -->|"Captures packet version"| audit holds -->|"Captures hold state"| audit approver -->|"Captures human sign-off"| audit audit -->|"Keeps downstream checkpoints after the planning gate"| restricted

Approval-gated execution fits because the manual fallback may be operationally prepared but must remain blocked until compliance leadership approves the packet.
The readiness ledger should tie reviewer staffing, queue segmentation, legal holds, protected-channel rules, and release boundaries to one current packet version.
Explicit holds should remain visible for missing reviewer coverage, unresolved legal constraints, or absent segregation-of-duties checkpoints instead of being normalized away.
The workflow should stop at the packet and hold register rather than recommending the authority lane again, re-establishing outage truth, or initiating manual screening.

Governance notes¶

Protected prerequisites such as reviewer coverage, legal-hold visibility, queue segregation, and release-boundary controls should be explicit before the packet can be treated as activation-ready.
Shared packets should minimize payment, counterparty, jurisdiction, and legal-analysis detail outside restricted compliance and legal channels.
Human compliance ownership is required before the packet becomes the authoritative basis for any manual-screening fallback activation.
Audit lineage should preserve which trusted outage references, staffing commitments, and protected holds changed across packet revisions during the outage window.

Evaluation considerations¶

Time from declared manual-fallback preparation request to a human-reviewable activation packet with complete staffing, queue, and hold state
Percentage of unresolved legal or staffing blockers kept visible in the hold register rather than hidden in a partially prepared fallback packet
Agreement between the workflow's packet and the final human-approved manual-screening activation gate used downstream
Stability of the readiness packet as outage scope, reviewer coverage, or protected release boundaries shift during the same critical period