Cross-Border Restricted Party Evidence

Source continuity and retained review

Use matchMode:"fuzzy" with minimumScore:92 for the conservative candidate workflow; conservative is not a valid enum value. candidate_scope discloses bounded trigram retrieval, short-name exact-only behavior, candidates evaluated, and returned-match truncation. It does not claim exhaustive fuzzy comparison or legal clearance.

SNAPSHOT-HEALTH records per-list counts, source-ID integrity, and HTTP representation timing separately from unknown individual-list publication dates. Optional expectedListSources and minimumListCounts use a caller-reviewed prior snapshot to fail closed if a list disappears or falls below its safety floor. No baseline is supplied by default; structural validity is not independent completeness against every issuing authority. Legitimate source removals require review of the baseline, not silently disabling its checks.

Preserve query_context_hash, matched-record fingerprints, and source snapshot hash with a human disposition. Supply them as previousQueryContextHash, previousRecordFingerprints and previousSourceSha256 on recheck. An unbound or changed query/source/record returns effective_disposition:NOT_REVIEWED and reopens the case while retaining the original caller assertion. Country mismatch never suppresses the candidate. Tests: node --test test_continuity_unit.mjs.

Review-oriented party-name evidence from the official U.S. International Trade Administration (ITA) Consolidated Screening List (CSL). The Actor accepts up to 100 party queries, compares each name against published primary names and aliases, and returns reproducible evidence rows with source identity, source fetch time, match score, published addresses and identifiers, change states, caller-asserted review disposition, and SHA-256 decision and batch receipts.

This product is useful to U.S. teams and to India- and China-facing suppliers, sourcing teams, marketplaces, and compliance operations that participate in U.S.-regulated transactions. Its coverage is the U.S. ITA CSL. It does not claim to cover every U.S., Indian, Chinese, or international restriction, and it never issues legal clearance.

Evidence decisions

• POTENTIAL_MATCH_REVIEW_REQUIRED: an exact or threshold-meeting fuzzy primary-name or alias candidate exists. Every candidate requires human due diligence against the cited official list.
• NO_CSL_NAME_MATCH: no name or alias in the completely downloaded source snapshot met the configured rule. This is not clearance or proof that the party is unrestricted.
• SOURCE_UNAVAILABLE: the official source could not be fetched or could not be validated as a complete CSL payload. This is deliberately distinct from a no-match.

Optional country and address values are consistency checks only. They never increase a candidate's name score or suppress a name match. A country or address conflict is evidence for review, not a reason to silently discard a candidate.

Input

{
  "queries": [
    {
      "reference": "supplier-1042",
      "name": "China Telecom Corporation Limited",
      "country": "CN",
      "address": "Beijing",
      "previousRecordFingerprints": ["sha256:..."],
      "previousDecisionReceiptHash": "sha256:...",
      "reviewDisposition": "NOT_REVIEWED",
      "reviewReference": "case-1042"
    }
  ],
  "matchMode": "fuzzy",
  "minimumScore": 92,
  "maxCandidatesPerQuery": 5,
  "previousSourceSha256": "sha256:...",
  "batchReference": "supplier-refresh-2026-08-23"
}

• queries: 1-100 objects. name is required. reference, ISO alpha-2 country, and address are optional.
• matchMode: exact or fuzzy (default fuzzy). Exact mode uses normalized full-name/alias equality.
• minimumScore: integer 85-100 (default 92).
• maxCandidatesPerQuery: integer 1-10 (default 5).

The deterministic fuzzy score is this Actor's candidate-retrieval score. It is not an ITA risk rating, recommendation, endorsement, or legal conclusion.

Monitoring and review workflow

• Re-submit the prior record_fingerprint values and decision_receipt_hash with each query to classify the observation as first-seen, unchanged, changed, or no-longer-present.
• Re-submit the prior source_sha256 once per batch to detect whether the complete official CSL snapshot changed.
• A caller may attach NOT_REVIEWED, CLEARED_FALSE_POSITIVE, CONFIRMED_MATCH, or ESCALATED. The output labels this CALLER_ASSERTED; it never overwrites the Actor's screening decision.
• Every output row carries one decision receipt and the entire batch shares one batch receipt, making partial or reordered exports detectable.
• The Actor does not retain the submitted portfolio. Schedule and persist prior receipts in your own controlled system when continuous monitoring is required.

Output evidence

Each row includes the query, decision and reasons; matched name, basis, score, and rank; published CSL record ID, entity number, party name, aliases, addresses, identifiers, programs, remarks, and source-list links; source URL, fetch time, snapshot SHA-256 and record count; a stable matched-record fingerprint; source/change health; review disposition; and decision and batch receipt hashes. legal_clearance is always false.

Responsible use

Use this Actor as a screening aid and audit trail, not as an autonomous approval, denial, onboarding, credit, employment, housing, or other consequential-decision engine. Resolve potential matches using the official Federal Register and the responsible agency's current list. Apply appropriate human review, legal advice, privacy controls, and retention limits. Do not treat a score as identity proof, wrongdoing, or an instruction to transact or refuse to transact.

ITA's own CSL guidance says the tool is an aid to electronic screening, possible matches require additional due diligence, and users should check the Federal Register and official agency lists before taking action.

Official source

• CSL information and responsible-use guidance: https://www.trade.gov/consolidated-screening-list
• Official downloadable JSON: https://data.trade.gov/downloadable_consolidated_screening_list/v1/consolidated.json
• ITA developer terms: https://developer.trade.gov/terms-of-service

See SOURCE-POLICY.md for the fail-closed source contract.

Tests

npm test
npm run test:live

The unit suite uses fixtures and failure injection. The bounded live suite performs three queries against one current, completely downloaded official snapshot: exact, fuzzy typo, and a synthetic no-match. It makes no account, publication, pricing, or outreach mutations.