The final version of FinCEN’s CDD requirements for financial institutions have now been issued, and they are already the subject of much discussion among AML/KYC practitioners. Much of this discussion has to date been devoted to risk models and risk-containment procedures that implement these models. Largely overlooked in the rush …
In April of 1945, as the war in Europe was in its final desperate phase, Winston Churchill took a momentary break from directing the entire British military and political effort in order to dash off a quick note to some (thankfully) nameless low-level official in the Foreign Office who had …
There’s no substitute for knowing… In previous posts, I’ve attempted to convey some sense of the linguistic and cultural diversity that personal names exhibit, especially when these names are converted from other writing systems and social contexts into the Roman (A-Z) alphabet and the naming system that predominates in the …
In this post, I’d like to provide an overview of the ways Islamic names encountered in AML/KYC contexts can differ from familiar Anglo/European names. I will emphasize those aspects that cause complications both for automated processing (searching and matching) and for human interpretations. In several previous posts, I have covered …
Those murmurs of hushed exasperation that have been gathering in Lower Manhattan since early December aren’t all about the collapse of energy stocks. A good many emanate from the financial institutions that make New York their home. And the issues that have the bankers mumbling are, in their way, just …
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 …
Breaking News That You Can Use Recently, all the major news channels carried a high-profile story about a Chinese businessman, Ng Lap Seng, who was arrested by the FBI for financial crimes, on the very same day that the Chinese President, Xi Jinping, arrived in Seattle, to begin his U.S. …
The Right Tool For The Job? There are so many ways to do name-screening in an AML/KYC context. Which one is right for you? OFAC tells you that they use the SOUNDEX and Jaro-Winkler name-matching algorithms, and that there is no need to spend your money on specialized (and expensive) …
The Helpful (and Thrifty) Fisherman Indulge me for a little bit, and let me stay with my fish story. So, you’ve headed to a hidden-away little lake in the deep north woods where pals have told you there are some trophy-sized bass to be caught. When you get there, you …
Do as I say, but not as I do In recent posts, I have pointed out a few of the main reasons why I believe that OFAC name-screening is fraught with so many uncertainties, making compliance unnecessarily difficult for many conscientious financial entities in the U.S. and around the world. …
