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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