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gateBankingCompliance — Sanctions, AML and DORA Decision Gate
// IMMO.QUICK · GATEBANKINGCOMPLIANCE · GATE 13 · OFAC/EU/UN · 6AMLD · DORA

A transaction isn't clean until three barriers fall.

gateBankingCompliance forensically seals that a banking transaction passes three sequential sub-gates, sanctions screening, anti-money-laundering with source-of-wealth proof, and DORA ICT resilience. Support for compliance departments, never a replacement for a regulator's own recognition as evidence.

In one sentence: gateBankingCompliance checks a banking transaction deterministically against three cascading sub-gates, sanctions, AML, DORA, and stops immediately at any failure, a second failure would be forensically irrelevant.
✓ RELEVANT IF...
  • You need to check cross-border payments or transactions with sanctions-list relevance
  • You need to make DORA ICT resilience and TPRM penetration testing forensically provable
✕ NOT RELEVANT IF...
  • You expect a regulator to automatically recognise the result as evidence
  • No banking or payment transaction and no ICT third-party review is involved
// The problem

"Court-proof" means cryptographically immutable, not regulator-recognised.

A core principle of this gate: cryptographic immutability since sealing is different from a supervisory authority's recognition as evidence. The gate delivers the deterministic proof, regulatory recognition remains a separate, downstream step we do not presume to grant.

// Architecture

Three sub-gates, cascading.

As soon as one sub-gate fails, the cascade stops. Checking continues no further, because a second failure would be forensically irrelevant once the first already triggers a block.

SUB-GATE 1
Sanctions Screening
Checks LEI and UBO against OFAC 31 CFR 501, EU 269/2014, EU 833/2014, and the UN consolidated sanctions list.
lei_verified_clear · ubo_verified_clear · sanctions_hit
SUB-GATE 2
GwG / AML
Checks cryptographic proof of source of wealth under the 6th Anti-Money-Laundering Directive (EU 2018/1673) and the German Anti-Money-Laundering Act.
source_of_wealth_proven · source_of_wealth_attestation_hash
SUB-GATE 3
DORA Resilience
Checks ICT risk management under Art. 9 DORA (EU 2022/2554) and a validated third-party risk management penetration test.
ict_risk_management_art9_attested · tprm_penetration_test_validated
An important distinction: NO_DECISION is not a pass
If the UBO check itself is missing, the gate returns NO_DECISION rather than BLOCK_SANCTIONS_MATCH. This is forensically correct: NO_DECISION means no decision could be made because the prerequisite is missing, not that a sanctions hit occurred. A NO_DECISION must never be read as a clearance.
// Test results

Five tested scenarios.

All values on this page are fictional test data and serve only to illustrate the gate logic.

Scenario SG1SG2SG3 Verdict
Fully cleanPASSPASSPASSBANKING_SEALED
Sanctions hit, material_block_mode activeFAILnot evaluatednot evaluatedBLOCK_SANCTIONS_MATCH
UBO not checkedFAILnot evaluatednot evaluatedNO_DECISION
Source of wealth missingPASSFAILnot evaluatedBLOCK_AML_SOW_MISSING
DORA ICT missingPASSPASSFAILBLOCK_DORA_TPRM_UNVERIFIED
Material block mode, UBO not checkedFAILnot evaluatednot evaluatedNO_DECISION
// Clarification

What gateBankingCompliance is not.

  • Not automatic recognition by a regulator. The gate delivers a cryptographic proof, not regulatory admission as evidence.
  • Not an independent sanctions list screening service. The gate checks against integrated lists, it does not maintain its own sanctions lists.

For compliance departments that want to make their banking transactions provable.

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