Know Your Data: OFAC and Hispanic Names

Why KYD Matters In my previous post, there was a chart that shows the extent to which a relatively small number of name-models predominate in OFAC SDN data. My ultimate purpose in providing that graphic was two-fold: To show that reliance on mediocre, Anglo-centric name-screening techniques such as SOUNDEX and …

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The Cultural Myopia in OFAC Search Tool & Lists Puts Banks at Risk

What makes a name “Anglo”? In my last post, I suggested that much of the confusion surrounding what might count as “minimally compliant” and/or “due diligence” by OFAC is a result of the way they describe and exemplify the recommended decision making process for name screening. IMHO,this process is culturally …

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OFAC Compliance: What Counts as Due Diligence?

“We’re from the Government, and we’re here to help.” OFAC supports U.S. financial institutions in their list-screening operations in several ways.  It provides: Current data on the many distinct lists of names of parties that fall under one or another of its enforcement actions, each of which is continuously updated …

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