Update to Rohas Legal AI: Regulatory

{
  "description": "Document sanctions screening of customers, counterparties, beneficial owners, controllers, vessels, aircraft, addresses, and transactions against applicable official lists and restrictions. Use for onboarding, periodic or event-driven rescreening, alert disposition, ownership-and-control review, and audit evidence.",
  "included_files": [
    {
      "relative_path": "agents/openai.yaml",
      "size_in_bytes": 322
    }
  ],
  "name": "sanctions-screening-documenter",
  "skill_md_contents": "---\nname: sanctions-screening-documenter\ndescription: >-\n  Document sanctions screening of customers, counterparties, beneficial owners,\n  controllers, vessels, aircraft, addresses, and transactions against applicable\n  official lists and restrictions. Use for onboarding, periodic or event-driven\n  rescreening, alert disposition, ownership-and-control review, and audit evidence.\n---\n\n# Sanctions Screening Documenter\n\nCreate a reproducible screening record, not a certificate that a subject is \"clear.\"\nDetermine applicable regimes and restrictions before interpreting a list result.\n\n## Intake\n\nObtain the screening date and timezone, transaction or relationship, jurisdictions\nand nexus, parties and roles, legal and trading names, aliases and scripts, dates and\nplaces of birth or incorporation, nationalities, addresses, identifiers, ownership\nand control, goods or services, routes, currencies, banks, vessels or aircraft,\nscreening tool and settings, prior alerts, licences, and escalation procedure.\n\n## Screening and documentation method\n\n1. Map sanctions jurisdiction from incorporation, nationality, location, conduct,\n   persons, goods, technology, transport, currency, payment chain, and contractual\n   commitments. Include UN measures only through the relevant domestic or regional\n   implementation unless the decision-maker is directly bound otherwise.\n2. Identify the current official lists, regime instruments, sectoral or activity-\n   based restrictions, ownership and control rules, general licences, exceptions,\n   reporting duties, and regulator guidance applicable at the screening time.\n3. Preserve list provider, list names, official source, publication or retrieval\n   timestamp, version or delta, dataset format, tool version, matching configuration,\n   transliteration, thresholds, and any source outage or fallback.\n4. Record the exact subject data screened and its provenance. Expand known aliases,\n   former names, native scripts, identifiers, addresses, and connected parties; do\n   not reduce screening to one Latin-script name.\n5. Review every candidate using multiple identifiers, list program and measure,\n   aliases, dates, locations, reference numbers, and narrative data. Treat a score\n   as triage, not proof of match or non-match.\n6. Analyse direct listing and current jurisdiction-specific ownership and control,\n   including aggregation, indirect holdings, control rights, trusts, intermediaries,\n   and entities acting for or on behalf of designated persons.\n7. Assess transaction restrictions beyond asset freezes: sectoral finance, trade,\n   services, investment, export, import, shipping, aviation, circumvention, and\n   facilitation. Verify licence or exception scope, conditions, parties, dates, and use.\n8. Classify the result as confirmed match, likely match, unresolved, false positive,\n   no candidate returned, or other policy category. State evidence, counterevidence,\n   reviewer, rationale, limitations, escalation, and approval.\n9. Follow applicable hold, reject, freeze, block, report, licence, recordkeeping,\n   confidentiality, and no-tipping-off procedures without taking irreversible action\n   solely from an automated alert.\n10. Set rescreening triggers for list changes, ownership or identity changes, new\n    transaction facts, geographic exposure, licence expiry, and periodic review.\n\n## Output\n\nProvide the applicability map, subject-data sheet, source and configuration log,\ncandidate comparison table, ownership-and-control analysis, transaction restriction\nreview, disposition and approvals, action and reporting record, limitations, and\nrescreening plan. Preserve enough detail for an independent reviewer to reproduce it.\n\n## Guardrails\n\nDo not call a fuzzy match conclusive, promise a false-negative-free result, use an\noutdated list silently, or ignore non-list-based restrictions. Do not disclose a\npotential match improperly or transact, freeze, reject, or report without the\nrequired authorised review and current jurisdiction-specific legal advice.\n"
}