‘Sally Jones’: Your Sanctions-screening Nightmare?


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It’s almost Halloween, and in the U.S. that means scary costumes and the tyranny of Pumpkin Spiced everything. But for some AML Compliance professionals, the United Nations Security Council and OFAC  last week delivered some news that is far scarier: One “Sally Jones” is now on sanctions-screening lists due to her alleged ISIS activities. 

For many institutions, that means screening hits. Lots and lots of false-positive screening hits. Because a name like “Sally Jones” and the surname “Jones” are ubiquitous in North America and the British Isles. And if your AML software solution for screening is not up to the challenge, you could be clearing false positives until Halloween 2016.

“Dealing with common names across cultures and countries depends on your sanctions-screening system and the latitude that Compliance has in that system. Also of major concern is the algorithm run for the fuzzy-logic searches. Some cast such a wide net that an avalanche of false positives bury the AML Compliance staff,” said Frank Cummings, AML Partners CEO.

Smart Software and Smart People Deliver Smart Sanctions Screening

But smart software and smart people can change that norm, according to Cummings: “Efficient and effective screening requires a deep understanding of the issues around sanctions and negative-news screening. That is the only possible way to escape the time-sucking drudgery of endless false-positive reduction projects that were actually built into old-fashioned screening systems.”

Cummings gets animated when he talks about the busy work and problem-causing features that are actually engineered into lesser AML Compliance software, either because of a lack of solution-oriented imagination or because the vendors are striving to make their consulting services indispensible. The Sally Joneses of the world help set the best AML screening systems apart from lesser options.

“If your job as an AML software designer is to help your customer do their job more efficiently and effectively, then you build software like our SURETY Suite. However, if your job is to make money at any cost, that is the other system,” Cummings said. “There is a scorched-earth mentality among some software vendors, and that is to make money at any cost. And so they do not accommodate the Sally-Jones-type problems that are so common in the world of AML/CTF compliance.”

The Right Algorithms, The Right Settings, & White Listing

Cummings describes how his SURETY-Sanctions Screening software solution handles a problem like “Sally Jones.” It starts with designing into the software itself the best fuzzy-logic and related algorithms to handle the screening of international names.

The next step is to teach Compliance professionals using this type of software how best to configure the software settings based upon their institution’s specific sanctions risk assessment. Compliance professionals also need to understand and anticipate how individuals might attempt to fool the filters—such as adding special characters in a name, reversing letters in the spelling, concatenating a name, and so on. This combination of high-quality screening software and smart use of screening settings results in fewer false positives from the outset, and then those hits are further reduced over time in SURETY-Sanctions Screening by using the white-listing feature.

Specifically, once you have done your research to clear a false positive, this software provides the functionality to whitelist your legitimate customer against a UID or sub-UID of a sanctioned individual. In essence, this white listing does not prevent a case from being created, but rather the case is created and then automatically waived by the system through the white-listing functionality. (Note that you should still periodically review these cases to ensure that your configuration is correct.)

The end result of a smart system like SURETY-Sanctions Screening is that there is no longer a need for month-long false-positive remediation exercises where institutions pay high-cost consultants to attempt to trick the list into not producing multiple false positives. And even these expensive and inefficient false-positive remediation projects are only good as long as there are no additional updates to the sanctions lists. As soon as an update is made, it’s time to start that project again—and, as you know, that happens quite frequently.

If this sounds familiar and you cringe at the thought of the Sally Joneses and her common-name counterparts from around the world, work smarter with a sanctions and negative-news screening system that puts your need for effectiveness and efficiency first.

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Sanctions Screening Questions?

If you would like to visit with Frank or with COO Jonathan Almeida about how SURETY solutions can improve the effectiveness and efficiency of your end-to-end AML Compliance needs, contact us today.