A key aspect of AML/CFT compliance is name screening, which involves checking the names of individuals and entities against watchlists, containing multiple lists of sanctioned or high-risk individuals and organisations, usually obtained through a name screening database provider.
In some cases, name screening may yield inconclusive results, meaning that there is not a clear match between the name being checked and a name on a watchlist. This can occur for a variety of reasons, such as spelling variations, the use of aliases, insufficient data, or errors in the data.
If you are dealing with an inconclusive name screening match, there are a few steps you can take:
Review the data, again
It is important to thoroughly examine the data related to the inconclusive name match, including the name being checked and the name on the list. Look for any discrepancies or differences that may provide an explanation for the inconclusive result.
Check additional sources, both external and internal sources
In some cases, an inconclusive match may be due to a lack of information. In these cases, you may want to check additional sources, such as public records or news articles, to see if you can find more information about the individual or entity in question.
Consider the context
Think about the context in which the inconclusive match is occurring. For example, if you are checking the name of a customer in the context of an onboarding process, you may want to consider other factors, such as their geographic location or the type of business they are engaged in.
If you are still unable to determine the status of the individual or entity in question, it may be helpful to seek guidance from a compliance officer or other expert. They may be able to provide additional resources or recommendations for how to proceed. Depending on the risk appetite of the financial institution, some may choose to treat inconclusive matches as positive matches. Others may chose to tag the match for a later review, and rely on other aspects of transactional or behavioural monitoring to trigger another review. It is also recommended to request for more information from the customer if the situation allows.
Dealing with inconclusive name screening matches in the context of AML/CFT compliance can be challenging, and at times frustrating, but there are a few steps you can take to try to resolve an inconclusive name screening match. By carefully reviewing the data, checking additional sources, considering the context, and seeking guidance as needed, you can help ensure that you are meeting your AML/CFT obligations and protecting your organisation from potential risk.
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