U.S. Treasury Department, Office of Foreign Assets Control
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 …
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. …
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 …
“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 …
