On the second of May 2019 OFAC published its “A Framework for OFAC Compliance Commitments” in which it listed its 10 “Root causes of OFAC Sanctions Compliance Program Breakdowns”.
Number 6 on the list is “Sanctions screening software or filter faults“, something that we specialise in, so we thought it would be a good time to look at just few of the failures – both close and exact – in matching we and OFAC have spotted over the years, without drawing attention to the culprits (fortunately all of these have been fixed).
| Customer Name | SDN (or HMT List) Name | Notes |
| U.I. International LTD. | U.I. International LTD. | Yes, the exact name doesn’t match, just because most of the name is made of noise words. |
| 2904977 CANADA, INC. | 2904977 CANADA, INC. | Another exact name match, but in this case the screening system didn’t match on company names starting with this many digits. |
| Africa Oil Corp | African Oil Corporation | Noise words help, and so does fuzzy matching, if you ever needed some evidence. |
| General Establishment for Agricultural Organisations | General Establishment for Agricultural Organizations | In this case Organisations was a noise word, but OrganiZations was not. Noise words help, but only when you do them right. |
| Mariana GALLON | Mariana GALLON ARISTIZABAL | Spanish names often drop their second surname, this is a crucial match to make as OFAC has many Spanish language names. |
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