Third-party red-flag escalation and decision record
- Created
- Last updated
Use this record when due diligence raises a concern that could affect onboarding, contracting, work or payment. The relationship owner records the activity at stake. Compliance helps assess what the evidence supports. The person authorised under your policy decides what may proceed and records who will enforce any restrictions.
Use one relationship record and repeat the issue block for each concern. Keep documents and sensitive identifiers in the approved case system and cite their references here. These fields are a suggested workflow. Apply the organisation’s authority, confidentiality and escalation procedures.
Identify the next commitment
Start with the activity that could happen before the concern is resolved. A contract signature, start of work and release of payment may need different decisions. For an existing commitment, route restrictions through the people who can assess contractual and operational effects.
| What to record | Entry or evidence reference |
|---|---|
| Relationship ID, legal entity and identifying reference | ____________________ |
| Relationship owner, activity, jurisdictions and stage | ____________________ |
| Next proposed commitment, deadline and affected amounts or services | ____________________ |
| Decision authority and any conflicts of interest | ____________________ |
| Current restriction, evidence it is in place, operator and review time | ____________________ |
Record one issue and the evidence needed
Write the fact that would affect the decision. Record what was observed, its source, and an alternative explanation where the evidence permits one. Distinguish a report or screening result from a verified finding. Use Supported, Concern, Unknown, or Not applicable with a reason. Blank means Unknown.
| What to record | Entry or evidence reference |
|---|---|
| Issue ID and specific proposition to establish | ____________________ |
| Observation, source and date, entity match and reliability limits | ____________________ |
| Evidence for or against, plausible alternative explanation and current status | ____________________ |
| Affected activity and exposure while the issue remains open | ____________________ |
| Specific evidence request, acceptable corroboration, owner and due date | ____________________ |
| Escalation route, receiving owner and deadline if evidence is late or contradictory | ____________________ |
Record what may proceed and when
Choose Proceed, Proceed with conditions, Defer, Decline or Exit. Record a referral separately so it cannot be mistaken for clearance. Use a conditional decision only where policy permits it and the condition can be enforced before the exposure arises. If signature itself creates the exposure, a condition checked after signature comes too late. A policy exception needs a named authority, rationale, scope and expiry, and remains subject to applicable obligations.
| What to record | Entry or evidence reference |
|---|---|
| Decision, exact activity covered, authoriser, authority and date | ____________________ |
| Evidence relied on, open issues and rationale | ____________________ |
| Permitted activity and activity that stays restricted | ____________________ |
| Condition, evidence needed to clear it, verifier and deadline | ____________________ |
| System or manual hold, who operates it and who can release it | ____________________ |
| Action if a condition fails or expires, and any authorised exception | ____________________ |
Follow the issue through to resolution or transfer
Keep the restriction and next review visible. Recheck the decision when a material fact changes, such as ownership, beneficiary, fees or delegates. Close as resolved once the evidence and disposition are recorded and any conditions affecting the issue are cleared. For a transfer, retain the linked case, the receiving owner’s acknowledgement and who controls every remaining restriction.
| What to record | Entry or evidence reference |
|---|---|
| Status (Open, Awaiting evidence, Awaiting decision, Monitoring conditions, Resolved or Transferred) | ____________________ |
| Next review, triggers, owner and actions if progress stalls | ____________________ |
| Resolution evidence and authority, or receiving case and acknowledgement | ____________________ |
| Remaining restriction, named operator and review date | ____________________ |
Worked examples
These examples use fictional data.
A name match is resolved
Case TP-21. A report names a business with a similar trading name. Compliance compares the registration identifiers against registry extracts REG-21 and REG-22. The identifiers establish different entities. The relationship approver records that this alert is resolved and makes the onboarding decision after the remaining checks.
A fee recipient is unexplained
Case TP-22. A proposal allocates part of an intermediary’s commission to a separate company. The fee schedule identifies the recipient but gives no basis for its entitlement. Procurement seeks corroboration. The authorised owner defers signature and payment, and finance confirms hold H-22. A referral to investigations stays open while acknowledgement is pending.
A proposed condition comes too late
Case TP-23. A sponsor proposes signing now and checking a delegate before work begins. Legal identifies an obligation triggered at signature. Compliance records the delegate’s role as Unknown. The authorised owner defers signing. Procurement owns the evidence request. Signature can be reconsidered after the evidence is assessed or an enforceable alternative is approved within policy.
Sources behind the workflow
- Documented due diligence and continuing oversight in a foreign-bribery prevention context. OECD Anti-Bribery Recommendation, Annex II A.6
- US prosecutorial evaluation guidance on business rationale, fees, third-party monitoring and red-flag disposition. US DOJ Evaluation of Corporate Compliance Programs, September 2024, section I.E
- Risk-proportionate enquiries in the UK bribery-prevention context. UK Ministry of Justice Bribery Act guidance, Principle 4
Sources
Check the original material below. How we use sources
- Primary sourceUK Ministry of Justice guidance, Principle 4
- Supporting sourceOECD Annex II, A.6