A growing trend in financial institutions is performing rule based auto elimination on secondary attributes. So for example when we have a match on a name; but a mis-match on a secondary attribute such as date of birth, nationality, or location; then the match will be eliminated before a person looks at it.
We at SQA Consulting only encourage this practise, but it should be done with care, computer based rules have no lee-way for applying common sense, so your rules should be precise and cover all eventualities.
Data Availability
We can setup all the rules we like on elimination by secondary identifier, however they only create value if we have data for the rules to act on. Some of the individuals on sanctions lists are shadows with obscure names, unknown heritage, dubious descriptions and ages, for these people we are unlikely to be able to do anything useful in screening. However for many we do have one or more secondary identifiers we can work with. Good lists – such as the OFAC SDN list, the UK HMT Asset Freeze, or the EU and UN lists – are enriched with these secondary identifiers, presented in a well formatted structure that a screening system can use. Other lists are less cooperative, but are enriched through research by various list vendors who supply these secondary identifiers to their subscribers.
The graph above demonstrates that over time the OFAC SDN list – the list that is foremost on most people’s mind due to their aggressive enforcement strategy – has progressively improved the availability of secondary identifiers. Currently over 44% of persons on the list have a date of birth, and an origin (place of birth, nationality, or citizenship), and a location. 89% of persons have 2 or more of these identifiers, and over 99% of persons have at least one of these identifiers.
By safely applying auto elimination rules we can achieve great efficiency improvements because we do have high levels of data available to us to work with. The key is applying the rules in a safe way, please read the rest of our growing set of articles on how to auto eliminate safely here.
