All sharing must be recorded, including downstream sharing (sharing by people who have received the information). This is the reason that Affinis(SDD) has the most intuitive and easy-capture method that can additionally be captured in a single click for every additional sharing.
Affinis(SDD) can enable capture centrally or provide a distributed structure where each internal person, whether Insider or Designated Person or other internal person can capture the flow of their own UPSI. Affinis(SDD) also enables a mid-path that enables SPOCs to capture for each department.
Of course, downstream sharing by external persons is a part of their own compliance responsibilities.
