As per the Executive Office’s Guidance on TFS for Financial Institutions and Designated Non-financial Business and Professions,⁵ name screening (whether automated or manual) must be performed prior to the onboarding of a customer and/or the facilitation of an occasional transaction and on an ongoing basis (at least daily) thereafter. As indicated above, name screening encompasses any data set within the LFI’s operations, separate from its transaction records, that may present a relevant sanctions risk indicator or be conducive to detection through screening on a periodic basis and prior to entering into a customer relationship.

Data relevant for name screening may include:

Not all data elements within an LFI’s records are relevant for sanctions screening. When determining what reference data should be screened, an LFI should identify the data within its operations and records that is relevant to sanctions risk, determine how it is relevant, ensure it is conducive to effective screening, and differentiate it from data that is not relevant or suitable to screening. For example, the names of individuals and entities with whom the LFI has a relationship are relevant for screening against name-based sanctions lists but not for geographic (region- or country-based) sanctions programs. Likewise, while the data contained in the addresses of such individuals and entities may not be directly relevant for screening against name-based sanctions lists, this data may assist in differentiating a true name match from a false name match when reviewing apparent name screening hits.

An LFI should also define other data elements (such as date of birth, nationality, and place of birth) that may be relevant for sanctions screening in some situations but not others. Date of birth, for example, is relevant as a distinguishing factor to assess a potential or a true match from a false match on an individual and might be used for screening in combination with another attribute, such as a name. In each case, LFIs should weigh up the relative incremental value of screening the data element against the reliability of the data and whether an alert against the data will meaningfully assist in detecting or preventing a sanctions risk that would not be reasonably detected through other controls, or by screening different data attributes. The screening criteria used by LFIs to identify name variations and misspellings should be based on the level of sanctions risk associated with the particular product or type of transaction. For example, in a higher-risk area with a high volume of transactions, the LFI’s interdiction software should be able to identify close name derivations for review.

An LFI’s reference data is typically maintained in electronic files and is most effective when screened through an automated process and repeated at defined intervals. The use of manual screening can be considered when the risk is sufficiently low and where the reference data cannot be sourced reliably, either electronically or in a format necessary for automated screening. For example, if an LFI has identified only a small population of names requiring screening, it may choose to forego investing in an automated screening system and instead manually input these names into an online screening filter.

⁵ Available at: https://www.uaeiec.gov.ae/en-us/un-page#.