A one-page map from ClearAgent's screening artifacts to the five program elements a BSA/AML program is examined against under the GENIUS Act and the FinCEN/OFAC rulemaking.
Every AML program under the rulemaking rests on five elements. Here is what ClearAgent produces for each one, and where it lives in the product.
Operator onboarding requires a named legal entity, and that entity explicitly configures the agent's spend policy — transaction limits, allowed chains, autonomous vs. supervised mode — at registration. This is a documented management decision about risk tolerance, not a system default. Policy changes made later via the spend-policy endpoint carry their own timestamp, so the record shows ongoing management engagement, not a one-time checkbox.
Every screen re-checks the counterparty and operator against OFAC SDN plus UN, EU, and UK sanctions lists at the moment of the transaction — not just at onboarding — so risk is reassessed continuously as the sanctions picture changes. The agent service directory extends that same screening to the broader population of agent-payable counterparties, giving your program a standing view of counterparty risk beyond your own transaction history.
Screening is policy-aware, not just a sanctions lookup: the 25-rule engine enforces the operator's declared spend policy alongside OFAC checks, so a payment can be held for exceeding a limit even when it's clean on sanctions. Every verdict ships with a signed receipt — cryptographically tied to the policy that produced it — so you can show a control fired on every payment, not just the ones that got flagged. Payments held for review get a named-officer disposition: who decided, when, what they saw, and why — an immutable record, not an editable note.
Screening records are chained per operator — each entry's hash includes the one before it — so a deleted or altered past record is detectable by recomputing the chain from genesis, independent of ClearAgent staying available. The exam bundle export packages that chain, the signed receipts, and the public verification key into a single offline-verifiable file for a date range, built specifically for the moment an examiner or independent tester asks for the file.
The API documentation lays out the screening methodology, rule precedence, and verdict meanings in the same terms your staff need to explain the program to an examiner — not just implementation detail for engineers. The compliance dashboard gives compliance staff a working view of screening activity and REVIEW dispositions, so the people running the program day to day are trained on the same artifacts the examiner will ask to see.
Five artifacts, each independently verifiable, that together answer "show me every payment was screened."
Every screen returns an ES256-signed receipt with the verdict, risk score, rule triggered, and hashes of the counterparty and policy involved — no raw PII. Verifiable against the public key at /v1/.well-known/jwks.json even with ClearAgent unreachable.
Each receipt carries a hash of the exact policy that produced the verdict, so a later policy change can't retroactively change what a past payment was screened against. The exam bundle ships the actual policy document alongside the hash, so a reader can check the two match without asking ClearAgent.
Every REVIEW disposition is an immutable, attributable record: officer name, email, timestamp, decision, reason, and a server-generated summary of what the officer had in front of them (verdict, rule triggered, prior-screening counts) — not officer-supplied, so it can't be backdated.
Every screen writes a row chained to the one before it for that operator. GET /v1/audit/verify recomputes the chain from genesis and reports the first entry where the stored and recomputed hashes diverge, if any.
Receipts, the policy snapshot, named-officer dispositions, the public JWKS, and a manifest (engine version, chain genesis) for a date range — downloadable via GET /v1/operators/{operatorId}/exam-bundle. Built to outlast the 90-day operational retention window — export before that window closes. Verifiable by anyone, with no ClearAgent account.