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  Sometimes Lowering the Bar is the Best Approach

About a month ago, Her Majesty’s Treasury made a significant change to its sanctions listings. Single name aliases like “MALIK”, “GIUSEPPE”, “ABDULLAH” and “FRANK” were removed as “a.k.a.” listings and instead moved to the “other information” section of the listing.

The implications of this change cannot be understated. HM Treasury has recognized the significant burden that matching on common single names has imposed on regulated institutions and has deemed identifying sanctioned individuals this way as setting the bar too high. As Accuity can attest to, sophisticated software and comprehensive compliance screening processes coupled with well-planned false positive reduction techniques certainly can differentiate a single name from part of a more complete name. However, there are solutions currently deployed by regulated institutions that do not have such capabilities. This means that, often, the “hits” generated by matching against single name aliases must be dealt with manually, raising a firm’s cost of compliance and lowering its efficiency. (Check your system’s match statistics and see how many hits you’re experiencing against single name aliases.)

The change instituted by HM Treasury has tackled this issue head on. We can only hope that OFAC and other regulators will follow suit by lowering the compliance screening bar — or at least this one aspect of it — and thus make a significant dent in the operational overhead of regulated firms.

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