RUSSIA SANCTIONS – BANK ROSSI – NAME SCREENING TESTING GUIDE ๐Does your Filter Detect “Bank Rossi”? OFAC’s does.๐
๐๐ฅTest Your Filter and Verify๐ฅ๐
๐ฅYesterday, additional names were added to the OFAC list. In reviewing the U.S. Department of the Treasury – OFAC List entry for THE “CENTRAL BANK OF THE RUSSIAN FEDERATION”, I noticed that the AKAs contained “BANK ROSSI, FEDERAL STATE BUDGETARY INSTITUTION”, but did not have an AKA with just “BANK ROSSI”. As your teams work to implement the latest OFAC list updates, please verify that variations you would typically seen are also stopped by your screening filters.
๐HOW TO USE THE GUIDE:
Search for BANK ROSSI in your filter.
๐ฉNON-DETECTION REMEDIATION: If not generating a match, contact your screening vendor to augment screening detection. If your vendor is unable to anything in the short term, add the missed name variation(s) to your in-house screening list as a stop gap.
๐ REMEMBER FILTERS AREN’T LIKE HUMANS: Screening filters are not intuitive, they don’t “see” what you and I “see” and they don’t have common sense.
๐Does your Filter Detect “Bank Rossi”? OFAC’s does.๐
๐๐ฅTest Your Filter and Verify๐ฅ๐
๐ฅYesterday, additional names were added to the OFAC list. In reviewing the U.S. Department of the Treasury – OFAC List entry for THE “CENTRAL BANK OF THE RUSSIAN FEDERATION”, I noticed that the AKAs contained “BANK ROSSI, FEDERAL STATE BUDGETARY INSTITUTION”, but did not have an AKA with just “BANK ROSSI”. As your teams work to implement the latest OFAC list updates, please verify that variations you would typically seen are also stopped by your screening filters.
๐HOW TO USE THE GUIDE:
Search for BANK ROSSI in your filter.
๐ฉNON-DETECTION REMEDIATION: If not generating a match, contact your screening vendor to augment screening detection. If your vendor is unable to anything in the short term, add the missed name variation(s) to your in-house screening list as a stop gap.
๐ REMEMBER FILTERS AREN’T LIKE HUMANS: Screening filters are not intuitive, they don’t “see” what you and I “see” and they don’t have common sense.
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If you would like Noe Compliance to review your filters, please contact us.
๐ DISCLAIMER:
: These test scenarios don’t focus on typos, testing should always consider fat finger, transliteration, translation, abbreviations, and/or typos.