Screening for sanctions names is tricky. As well as people trying to hide their identity by using an alias, names can be presented for screening in all sorts of different ways. Matching a name on a sanctions list requires a screening system with complex algorithms that will identify the match without also creating a significant number of false positives that analysts need to work through.
One of the factors that determine how many false positives will be generated is the commonality of the name. If a relatively common name is screened, say Ricardo Gonzales, logic dictates that you will get a larger volume of hits than if you screened a very obscure name. This will be further exaggerated if you are screening for PEPs and Adverse Media as well as sanctions.
At SQA Consulting, one of the tools we have built to support our clients with their screening challenges is the Ethnic Name Origin tool. As well as determining where in the world the name comes from, it measures the commonality of the name. A hit on an obscure name is more likely to be a true hit, just based on the law of averages.
We thought it would be interesting to look at the commonality of names that have been listed as Specially Designated Nations (SDNs) by OFAC[1]. The chart below shows the number of SDNs with names of different commonality, where 0 is a very common and 100 is very obscure.
There is some relatively good news to be taken from this chart – the majority of SDN names are at the more obscure end of the scale and therefore should – in theory – be easier to find. However, there is still a long tail of more common names within the list. With high volumes of false positives, this is ‘needle in a haystack’ territory.
So this is the theory, but what is the reality? That depends on having a finely tuned screening engine configured to identify matches and weed out as many false positives as possible. At SQA Consulting, we test, assurance and benchmark screening systems so that you know how effectively and efficiently yours are performing.
Please contact us if you would like to discuss this in more detail.
[1] The US Office of Foreign Assets Control which publishes lists of individuals and companies owned or controlled by, or acting for or on behalf of, sanctions targeted countries.
