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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