More fines have been handed out for transactions to places rather than to names on lists, yet we still spend far more time and effort chasing names of people and organisations, than we do looking for where our clients are based, and where they are transacting.
Whilst most screening systems will look for basic country names like Iran and Syria, we don’t always get the country name, and certainly not always in the right place. Even when we do get it then it can be spelt in substantially different ways than we are used to or expecting.
To combat this we use a CTRP (Cities, Tows, Regions, and Ports) list which will have place names (including country names) in lots of different languages and character sets, and also feature keywords like “Syrian”, “Iranian” and “Persian” (companies have been fined by OFAC for not doing this).
Defining how far you want to go with geographic terms can be difficult, we hold 242,015 different place names within Iran alone on our gazetteer, and we don’t expect you to screen all of them. Selecting what you want to screen involves some judgement calls, for example do you want airports as well as sea ports? Do you want towns smaller than 100,000 population.
Your selection will be based on your risk, which in this case will depend on your business and its underlying technology. For instance there is no point screening Cyrillic versions of large towns in North Korea, if your data is all in Latin characters.
Instead of going for a set of definitions such as every town over 100,000 populations, you can go for a top ten approach. This gives a much tighter scope and can alleviate the potential number of false positives that can be generated by CTRP screening. In a top ten scenario each place name can be assigned points for size and status, such as points for being a capital city, or a point for every 100,000 population in a town, more points for being an international airport. Terms that would match to multiple places can then be determined that would match to the port, airport, region and city.
SQA Consulting provide CTRP lists to some of the world’s biggest banking brands, and smaller institutions alike, each customised to their needs.
Please pick up our financial crime brochure here.
