Streamlining Sanction and OFAC Review from Submission Packages — Property & Homeowners, Specialty Lines & Marine, General Liability & Construction

Regulatory risk doesn’t wait for clean spreadsheets. It hides inside sprawling submission packages — broker emails, ACORD applications, policyholder questionnaires, schedules of locations, vendor rosters, ownership charts, and even scanned passports. For the Risk Manager, the challenge is stark: prove that every named insured, additional insured, lender, vessel, beneficial owner, and counterpart has been screened against OFAC and other sanctions regimes before binding, renewing, paying, or facilitating a transaction. The stakes are high; OFAC is a strict liability regime. But the data you need is scattered, inconsistent, and often unstructured.

This is precisely where Nomad Data’s Doc Chat changes the game. Doc Chat for Insurance ingests entire submission packages — thousands of pages across PDFs, emails, spreadsheets, scanned documents, and images — then extracts the people, entities, vessels, addresses, and identifiers you must screen. It normalizes spellings and transliterations, maps aliases, and generates structured entity lists that can be automatically checked against your OFAC, EU, UK HMT, UN, BIS, and commercial watchlist feeds. The result: a defensible, auditable AI compliance check against OFAC for insurance placements in Property & Homeowners, Specialty Lines & Marine, and General Liability & Construction — completed in minutes, not days.

Why sanctions screening from submissions is so hard for a Risk Manager

The modern submission is a haystack of unstructured references to legal and natural persons. The Risk Manager must find every needle: named insureds, DBAs, parent entities, subsidiaries, directors, ultimate beneficial owners (UBOs), vessels, charterers, mortgagees/loss payees, certificate holders, subcontractors, vendors, and sometimes even counterparties in lease or charterparty agreements. In Property & Homeowners and GL/Construction, this complexity often arises from additional insured endorsements, mortgagee clauses, and large contractor/vendor schedules. In Specialty Lines & Marine, it’s compounded by vessel identities, call signs, IMO numbers, flag states, and voyage details.

Property & Homeowners

Residential and commercial property submissions routinely bundle ACORD 125/140 applications, Statements of Values (SOVs), lender schedules, additional insured endorsements, and schedules of locations. Broker submissions may include property manager rosters, owner LLCs with layered holding companies, and cross-border interests. The Risk Manager must ensure every named or referenced party — including mortgagees and property managers — is screened, that potential 50 Percent Rule implications are understood, and that any restricted jurisdiction exposure (e.g., sanctioned regions) is surfaced early.

Specialty Lines & Marine

Marine and specialty placements intensify the challenge. Broker submissions may reference vessels by current and former names, call signs, MMSI, and IMO numbers; charterparties; P&I club certificates; bills of lading; and port calls or STS transfer histories. Different transliterations of the same owner’s name, flag changes, and shell-company ownership can obscure risk. The Risk Manager must confirm that the vessel, registered owner, beneficial owner(s), technical and commercial managers, charterers, and counterparties are cleared against OFAC SDN and other lists — and that the voyage or cargo doesn’t implicate embargoed jurisdictions.

General Liability & Construction

GL and construction submissions often involve large subcontractor rosters, vendor master lists, W-9s, COIs, OCIP/CCIP enrollment documents, and site-specific endorsements that bring dozens or hundreds of counterparties under the policy umbrella. A single additional insured endorsement can pull in a municipality, a GC, and dozens of subs. The Risk Manager must verify that these entities are not sanctioned and that any foreign counterparties linked to projects are screened, especially where imported equipment or cross-border contracts are involved.

How these reviews are handled manually today

Most teams still rely on manual review: an analyst opens the broker submission, skims ACORD applications (125/126/140), reads attachments, copies names into a spreadsheet, and runs each name through a sanctions screening tool. When names appear in emails or addenda, or when brokers send updated attachments, the cycle repeats. Variants, misspellings, and transliterations trigger false positives that must be cleared one by one. Addresses and identifiers are inconsistent; beneficial owner references hide in footnotes or org charts in image-only PDFs.

For the Risk Manager, the process is error-prone and slow. Turnaround time expands, underwriting SLAs slip, and the risk of missing a sanctioned party rises with every page. Worse, manual methods rarely capture the full set of parties — additional insureds named deep in endorsements, lenders listed only on mortgagee clauses, or vessel managers referenced only in a charterparty email. As volumes scale, you hire more people or accept more risk.

What good looks like: a comprehensive, consistent, auditable workflow

Sanctions compliance at underwriting should produce a complete, de-duplicated entity universe for every submission, even when the broker provides scattered or inconsistent information. It should apply the OFAC 50 Percent Rule, screen jurisdictional exposures (e.g., Crimea/Sevastopol, Donetsk, Luhansk; Cuba; Iran; North Korea; Syria; certain Russian sectors), and maintain an audit trail that ties each clearance decision to the exact page and context in the source file. It should also re-run screening at key lifecycle events: endorsement requests, midterm changes, renewals, and claim payments that might constitute a service for a blocked person.

How Nomad Data’s Doc Chat automates sanctions and OFAC screening from submissions

Doc Chat is a suite of purpose-built, AI-powered agents designed for insurance documents. It ingests entire submission packages — PDFs, emails, spreadsheets, images, and zipped folders — and produces a structured, verifiable output tailored to your sanctions program. Unlike generic OCR or rules engines, Doc Chat reads like a domain expert and captures nuanced references across inconsistent formats. As we outlined in Beyond Extraction: Why Document Scraping Isn’t Just Web Scraping for PDFs, the critical value is inference: assembling the full entity map from fragments scattered across pages.

End-to-end automated pipeline

Here’s how Doc Chat operationalizes sanctions checks for Property & Homeowners, Specialty Lines & Marine, and GL & Construction:

1) Ingest and classify
Doc Chat ingests thousands of pages per file and classifies document types automatically: ACORD forms (125/126/140), SOVs, W-9s/W-8BEN-E, organizational charts, broker cover letters, additional insured endorsements, mortgagee clauses, subcontractor/vendor lists, marine certificates, charterparties, bills of lading, P&I club certs, policyholder info sheets, and spreadsheet attachments.

2) Extract the entities you must screen
Using LLM-driven extraction tuned for insurance, Doc Chat pulls names, DBAs, addresses, countries, tax IDs (EIN), LEIs, DUNS, license numbers, email domains, and for marine: vessel names, former vessel names, IMO numbers, MMSI, call signs, flag states, managers, owners, and charterers. It also harvests names referenced in narrative text — broker emails, footers, and policy endorsements — and builds a single entity graph with source citations.

3) Normalize, de-duplicate, and handle transliterations
The system standardizes name orderings, handles diacritics, converts Cyrillic/Arabic/Chinese to Latin equivalents, and detects likely alias clusters. It collapses duplicates across submissions, attachments, and email bodies, resolving "ABC Intl. Ltd." and "ABC International Limited" to one canonical entity, while preserving original variants for screening.

4) Screen against sanctions and restricted lists — your way
Doc Chat connects to your existing screening stack: OFAC SDN/SSI, EU Consolidated List, UK HMT OFSI, UN sanctions, BIS Entity List and MEU List, as well as commercial providers like World-Check or Dow Jones (via your licenses). It can also run geo-controls by comparing locations, ports, or flags against restricted jurisdictions. Results come back as structured hits with confidence scoring and page-level links to the source mentions.

5) Apply rules like the OFAC 50 Percent Rule
Where ownership information exists (org charts, shareholder tables, beneficial ownership attestations), Doc Chat aggregates ownership percentages to identify blocked persons who collectively own 50% or more. It flags risks even when individual owners aren’t on the SDN list, providing the evidence trail that supports the risk decision.

6) Generate a complete audit trail
Every extracted entity is linked to the page and snippet it came from. Findings are explained with citations so Compliance, Legal, and audit teams can verify in seconds. This mirrors the page-level transparency claims organizations value, as described in our case study with GAIG: Great American Insurance Group accelerates complex claims with AI.

7) Real-time Q&A across the entire file
Doc Chat isn’t one-and-done extraction. Risk Managers can ask: “List every named insured, additional insured, mortgagee, and lender; include addresses, countries, EINs, and page citations.” Or: “Show all vessels and their IMO numbers; indicate any prior names and current flag state.” Or: “Do any counterparties touch Russia, Iran, Cuba, Syria, North Korea, or embargoed regions?” Answers return instantly with citations and exportable data.

Which parties must be screened from submission packages?

Sanctions exposure in insurance goes far beyond the named insured. Doc Chat ensures no stakeholder slips through the cracks by extracting and organizing the full party universe commonly found in Property & Homeowners, Specialty Lines & Marine, and GL & Construction submissions:

- Named insureds, additional named insureds, DBAs, and affiliated entities
- Ultimate beneficial owners (UBOs), directors, officers, and control persons
- Additional insureds added via endorsements (e.g., owners, municipalities, GCs)
- Mortgagees, loss payees, lenders, and certificate holders
- Property managers and third-party administrators
- Vendors, suppliers, and subcontractors named in rosters or COIs
- Marine entities: vessel owners, registered owners, beneficial owners, operators, managers, charterers
- Counterparties in charterparties, leases, and service agreements

“AI compliance check against OFAC insurance” — built for real-world submissions

Searches for AI solutions often lead Risk Managers to ask for an “AI compliance check against OFAC insurance.” The need is clear: accelerate and improve OFAC and sanctions reviews within the submission workflow without sacrificing rigor or auditability. Doc Chat was built precisely for this. It handles the messy realities of real submissions and the nuanced decisions Risk Managers must make.

Special focus: marine sanctions, vessels, and voyage context

Marine placements carry unique risks. A vessel may have changed flags; its registered owner can be a shell; its beneficial owners may be spread across jurisdictions. A voyage could traverse restricted ports or involve cargo from embargoed origins. Doc Chat:

- Extracts vessel names, former names, IMO numbers, MMSI, call signs, and flag states from broker submissions, P&I certificates, or charterparties.
- Normalizes vessel identity despite renamings or flagging changes.
- Screens vessel and ownership entities against OFAC, EU, UK HMT, and UN lists via your provider.
- Surfaces mentions of ports, voyages, counterparties, or cargo that might trigger sanctions controls.

Because Doc Chat links every finding back to the exact page, Risk Managers can rapidly validate, clear false positives, or escalate potential violations with confidence.

How organizations try to “automate OFAC/sanction review commercial submissions” today — and why it falls short

Teams commonly stitch together OCR tools, rules-based extractors, and generic screeners, only to discover the method breaks under real-world variability. As we explain in Beyond Extraction, real documents require inference. Submission packages hide entities in narratives, tables, scans, and emails. There are multiple ways to refer to the same party, and the true owners are rarely listed in one place.

Doc Chat solves the last-mile problems: it reads like an insurance expert, consolidates scattered references, and produces a complete, structured entity list without brittle templates. For organizations that simply want to “automate OFAC/sanction review commercial submissions,” this depth is the difference between a demo that works on pristine PDFs and a production system that stands up to audits.

What Doc Chat delivers out of the box

Nomad Data designed Doc Chat for the pressures of insurance operations. From day one, Risk Managers can expect:

- Ingestion at scale: process entire submission folders in minutes; our engine handles massive files with consistent accuracy, as discussed in The End of Medical File Review Bottlenecks.
- Structured outputs tailored to your playbooks: CSV/JSON feeds listing entities, roles (e.g., named insured, vessel owner), identifiers, countries, and citations.
- Integration with your screening stack: leverage your licenses and systems for list checks; Doc Chat provides clean, normalized inputs and consumes screening outcomes.
- Real-time questions: ask Doc Chat for clarifications, supporting evidence, and summaries; export answers into the underwriting file.

The manual-to-automated shift: what changes in your day-to-day

Risk Managers typically see an immediate change in how work gets done:

Before: Analysts read page by page, copy/paste names into a spreadsheet, chase missing context in email threads, run each name in a screening tool, and compile notes for Compliance. Cycle time balloons with each false positive or revised submission.

After: Doc Chat ingests the package, generates a comprehensive entity list with roles and identifiers, screens through your stack, and returns a decision-ready report with citations. Analysts focus on clearing true matches and advising on edge cases (e.g., 50 Percent Rule aggregation) rather than hunting for names.

Business impact: time, cost, accuracy, and defensibility

Compliance outcomes improve when you standardize and accelerate the process without compromising rigor. With Doc Chat, Risk Managers see:

- Time savings: Submission screening moves from hours to minutes, even for complex marine or construction cases. Surge volumes (seasonal or event-driven) no longer require overtime or temp staff.
- Cost reduction: Analysts spend fewer hours on copy/paste and false-positive triage; you scale without adding headcount.
- Accuracy: LLM-driven extraction reduces missed parties; ownership aggregation flags hidden blocked ownership; geo-controls identify embargoed-region exposures.
- Defensibility: Page-level citations and a complete audit trail reduce regulatory risk and speed internal reviews by Compliance, Legal, and Audit.

Examples of Risk Manager queries Doc Chat answers instantly

Real-time Q&A is a turning point for sanctions compliance in underwriting. Common prompts include:

- “List every entity that must be screened (named insureds, additional insureds, mortgagees, lenders, vendors, subcontractors), with countries, identifiers, and page citations.”
- “For all vessels mentioned, provide IMO, MMSI, call sign, flag state, and all known former names.”
- “Do any counterparties, owners, or directors appear on OFAC/EU/UK/UN lists? Show the match candidates and the source text.”
- “Aggregate beneficial ownership to determine if any blocked persons collectively own ≥50%.”
- “Highlight any references to Russia, Iran, Syria, Cuba, North Korea, Crimea/Sevastopol, Donetsk, or Luhansk.”

Data types and documents Doc Chat handles for this use case

Doc Chat is tuned for the document soup inherent in Property & Homeowners, Specialty Lines & Marine, and GL & Construction. Typical sources include:

- Broker submissions and cover letters
- ACORD 125/126/140, supplemental questionnaires
- Policyholder info sheets, KYC questionnaires, OFAC attestations
- Organizational charts, shareholder tables, UBO attestations
- Statements of Values (SOVs), schedules of locations
- Additional insured endorsements, mortgagee/loss payee clauses
- Vendor and subcontractor rosters, COIs, W-9s/W-8BEN-E
- Marine: charterparties, bills of lading, P&I certs, vessel registries
- Email threads with attachments, spreadsheets, and scanned images

Security, privacy, and audit readiness

Sanctions screening touches sensitive business information. Nomad Data operates with enterprise-grade security controls and verifiable audit trails. Outputs include time-stamped logs, source citations, and decision summaries suitable for internal audits and regulatory inquiries. As adoption scales, Doc Chat integrates with intake portals, underwriting workbenches, and GRC systems without disrupting existing oversight.

Why Nomad Data is the best partner for sanctions screening from submissions

Doc Chat’s advantages extend beyond pure technology:

1) Built for volume and complexity
Doc Chat ingests entire submission files — thousands of pages — and maintains consistency from the first page to the last. Where human accuracy declines with fatigue, Doc Chat’s accuracy remains steady.

2) The Nomad Process
We train Doc Chat on your playbooks, document types, and compliance standards. The system mirrors your definitions of “who must be screened,” your escalation thresholds, and your approval paths.

3) White-glove delivery and rapid time to value
Implementation takes roughly one to two weeks. We configure outputs, connect to your screening providers, and tune extraction to your lines of business — Property & Homeowners, Specialty Lines & Marine, and GL & Construction.

4) Real-time Q&A with citations
Ask Doc Chat to explain a hit, show source pages, or differentiate a false positive. This transparency maintains trust with Compliance, Legal, and Audit.

5) Proven on real insurance files
As highlighted in our GAIG story, Doc Chat delivers both speed and explainability on high-stakes insurance documents, not just tidy samples.

From data entry to decision intelligence

Many sanctions processes devolve into data entry: find the names, type them into a portal, export a PDF. The hidden cost is enormous. As we discuss in AI’s Untapped Goldmine: Automating Data Entry, automating document understanding frees skilled teams from rote work and elevates the quality of decisions. For Risk Managers, this shift means spending time on edge cases, policy, and oversight — not manual extraction.

How Doc Chat fits into your existing underwriting and compliance flow

Doc Chat is designed to meet you where you are:

- Early adoption: Drag and drop submission folders; export entity lists to CSV; screen via your existing tools.
- Integration: Connect to intake portals, underwriting systems (e.g., Guidewire, Duck Creek), GRC tools, and your screening provider via API.
- Governance: Enforce approval workflows, store audit packets, and enable periodic re-screening (e.g., at renewal or midterm changes).

Operationalizing continuous screening

Sanctions risk is not a one-time check. Doc Chat can trigger re-screens at key events: new endorsements, midterm entity changes, or claim payments that risk a “service” to a blocked person. Automated re-checks ensure continued compliance across the policy lifecycle — a critical capability for GL/Construction projects with evolving subcontractor rosters and for marine risks with voyage changes.

Illustrative scenario: marine hull and cargo placement

A wholesale broker submits a folder for a marine hull and cargo placement. Inside are ACORD forms, a charterparty, P&I certs, an ownership chart, and a spreadsheet of vessels. Doc Chat ingests the folder, extracts vessels with IMO/MMSI/call signs, identifies the registered owner, technical manager, and commercial manager, and normalizes multiple name variants. It screens all entities via your provider and flags an SSI match for one manager and a potential OFAC 50% ownership risk based on the ownership chart. The Risk Manager receives an output with:

- A consolidated entity list (roles, identifiers, countries)
- Screening results with confidence scores
- Page-level citations for each entity and ownership percentage
- A summary of recommended actions (e.g., exclude the vessel, seek representations, escalate to Compliance)

A process that previously took a day of manual work (and still risked missing a manager named only in the charterparty email) is completed and defensible within minutes.

Illustrative scenario: GL & Construction with a large subcontractor roster

For a major construction project, the submission includes ACORD 125/126, additional insured endorsements, W-9s, and a vendor/subcontractor list of 250 names. Doc Chat extracts every entity, cleans duplications, normalizes countries and EINs, and runs the entire list through your screening stack. It returns a sortable table with matches, potential false positives, and the exact page citations that justify each entity’s inclusion. Compliance reviewers can clear or escalate quickly, maintaining underwriting speed without raising risk.

Key metrics Risk Managers can expect

While results vary by portfolio and process, organizations commonly report:

- 80–95% reduction in time to compile and screen entity lists from submissions
- 30–60% fewer false-positive escalations due to better normalization and context
- Substantially lower leakage risk from missed parties (e.g., mortgagees, additional insureds, vessel managers)
- Stronger audit posture with page-level citations and standardized outputs across teams

Implementation: 1–2 weeks to your first automated sanctions reports

Nomad Data’s white-glove approach gets Risk Managers productive fast. In week one, we map your document types, define “who must be screened” per line of business, configure outputs, and connect to your screening provider. In week two, we validate on real submissions, tune edge cases (e.g., vessel identity resolution), and go live with your team. Training focuses on using real-time Q&A to explain results, clear matches, and produce audit packs.

Addressing common concerns

Will AI hallucinate entities? Doc Chat is constrained to your documents and focuses on extraction with citations. If it can’t find a datum, it says so, and you see exactly what was (and wasn’t) in the file.

What about data security? We operate with enterprise-grade controls and provide a fully auditable trail. Your sanctions screening remains within your providers and policies; Doc Chat orchestrates and documents the process.

Is this just generic summarization? No. Doc Chat is purpose-built for insurance decisions and document structures. It doesn’t merely summarize — it extracts, normalizes, cross-checks, and explains, at scale.

Why act now

Sanctions regimes are dynamic and enforcement is intensifying. Manual screening can’t keep pace with submission volume, complexity, or rising expectations for auditability. With Doc Chat, the Risk Manager can confidently deliver a fast, complete, and defensible sanctions process for Property & Homeowners, Specialty Lines & Marine, and GL & Construction — and do it at enterprise scale.

Next steps

If you are exploring ways to automate OFAC/sanction review commercial submissions or seeking an AI compliance check against OFAC insurance tailored to your underwriting and compliance standards, see how Doc Chat works in practice. Visit Doc Chat for Insurance and ask us to run a real submission package. In minutes, you’ll have a complete, auditable entity list with citations and screenings — a foundation your Risk Management team can trust.