Those common names can be so frustrating on that OFAC list! A few of the things I look at:
1. Does the customer have an interest bearing account, and do we have any outstanding "B" notices? If the name and SSN have been okay with the IRS, and the SSN does NOT appear on the OFAC list, then I'll take that as an indication that it is likely to be a false positive.
2. Is the customer's address in the U.S.? If so, how long has the customer been at their current address? If they've been at a U.S. address for more than a couple of years, then it is likely to be a false positive.
3. Did you get an in-state Driver's License on the customer, or did you use a passport? If you obtained an in-state Driver's License, and your staff is reasonably certain it was genuine, then I would say it is likely you have a false positive.
The only way to be really certain, I suppose, is to call OFAC and send them the identity information you have. However, from my past experience, OFAC was not too thrilled with me when I called with 5 different Carlos Gonzales's.
As I recall, my query was met with a reponse something along the lines of "Oh honestly - do YOU think these people are the same as the OFAC list?
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'