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#1629041 - 11/16/11 03:34 PM OFAC filters - glued names - OCC looking at
Madawaska Offline
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We have the OCC on-site performing an examination of an affliate company.

They have drilled down and tested our two OFAC filtering systems to "glued names". The names tested did result in failures for various name variations and aka's on the SDN list as it should have, just not on the glued names.

Please let me know if your bank is filtering for glued names. Ex: MarySmith and/or SmithMary

Also, is this something fairly new in the filtering systems?

I need to get a feel for how much glued names are being used in banks and why the OCC is now looking for it.

Thanks! I appreciate any and all replies to my inquiry.

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#1629069 - 11/16/11 03:53 PM Re: OFAC filters - glued names - OCC looking at Madawaska
Hrothgar Geiger Offline
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The OCC is spending more time looking at the implementation, tuning and effectiveness of various compliance and AML monitoring systems. They are also looking more deeply into the models and algorithms used in banks' 'home-grown' systems.

As a result, OFAC and sanctions monitoring programs are being put through a more rigorous exam process.

I think that banks, or really any company using sanctions screening software should consider independent testing/evaluation of their sanctions software before a regulator does it for them.

Remember that part of OFAC's penalty scheme these days is to take into account the overall program, and systems in place. It wouldn't be a big leap for them to consider 1) that an institution's screening is deficient, and 2) that the institution never tested it effectiveness in the first place.

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#1629073 - 11/16/11 03:55 PM Re: OFAC filters - glued names - OCC looking at Madawaska
BC78a Offline
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In 3 banks - I never tested for glued names
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#1629443 - 11/16/11 10:00 PM Re: OFAC filters - glued names - OCC looking at BC78a
devsfan Offline
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FDIC examiners were also very interested in glued names, last name first, etc

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#1630466 - 11/18/11 07:22 PM Re: OFAC filters - glued names - OCC looking at Madawaska
PeeWee Offline
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For the "glued" names to be an issue, am I correct in saying that the names would have to go through the OFAC screening process "glued"?

One of our OFAC processes is to screen all customers nightly through a software that receives an extract from our core processing system. Since the first and last names come from two different fields in the core system, I don't think I would have an issue with "glued" names.

Any thoughts or further explanation (if I'm not understanding this concept) would be appreciated as we'll be going through our first OCC exam soon.

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#1630483 - 11/18/11 07:34 PM Re: OFAC filters - glued names - OCC looking at PeeWee
Hrothgar Geiger Offline
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In practice, you would see glued names on transactions, like a wire transfer, or IAT, instead of customer records.

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#1630554 - 11/18/11 08:37 PM Re: OFAC filters - glued names - OCC looking at Hrothgar Geiger
PeeWee Offline
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Many thanks - that helps me understand the concept much better.

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#1630972 - 11/21/11 06:34 PM Re: OFAC filters - glued names - OCC looking at PeeWee
Getting_Grayer Offline
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I apologize for not knowing this, but what is a "glued name"?

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#1630983 - 11/21/11 06:42 PM Re: OFAC filters - glued names - OCC looking at Getting_Grayer
E.E.G.B Offline
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If I understand it correctly, it's when the first and last names are run together. So in the first post the examle is Mary Smith. Glued together it would be MarySmith. If your system runs last name first, it would be SmithMary instead of Smith Mary.

Where I think it gets more interesting is when it's intials - ie, J D Eaks becomes JDEAKS. That seems to throw a lot of the sytems.
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#1630984 - 11/21/11 06:43 PM Re: OFAC filters - glued names - OCC looking at Madawaska
Elwood P. Dowd Offline
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Quote:
Ex: MarySmith and/or SmithMary


Apparently, it means they stick the first name & surname together, no space. (Never heard of it before either wink )
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#1630990 - 11/21/11 06:46 PM Re: OFAC filters - glued names - OCC looking at Elwood P. Dowd
edAudit Offline
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I was under the impression it was First and Middle names:

Mary lou

Marrylou
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#1630999 - 11/21/11 06:52 PM Re: OFAC filters - glued names - OCC looking at edAudit
Elwood P. Dowd Offline
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Chuckle for the day: Googled the term and this thread was the first hit. grin It's possible that there is no uniform definition.
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#1631001 - 11/21/11 06:54 PM Re: OFAC filters - glued names - OCC looking at Elwood P. Dowd
edAudit Offline
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Originally Posted By: Ken_Pegasus
Chuckle for the day: Googled the term and this thread was the first hit. grin It's possible that there is no uniform definition.


That would make us the experts smile
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#1631042 - 11/21/11 08:00 PM Re: OFAC filters - glued names - OCC looking at edAudit
HDavidson Offline
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experts= X is the algabraic equivalent of the unknown and a "spert" is nothing more than a drip under pressure

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#1631189 - 11/22/11 12:47 PM Re: OFAC filters - glued names - OCC looking at HDavidson
NotDoneYet Offline
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When I saw this thread, I did my own testing, then contacted our third party WatchDog, who did their own testing of glued names.
And they were able to confrim they do support glued names. For their testing, they took a four part name and stuck the first to second, second to third, third to fourth and verified they got the same "hit" every time.

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#1631222 - 11/22/11 01:56 PM Re: OFAC filters - glued names - OCC looking at NotDoneYet
rlcarey Online
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It really should not make much of a difference on OFAC systems that use phonetic algorythyms.
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#1631261 - 11/22/11 02:51 PM Re: OFAC filters - glued names - OCC looking at NotDoneYet
E.E.G.B Offline
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Originally Posted By: jcaldwell
When I saw this thread, I did my own testing, then contacted our third party WatchDog, who did their own testing of glued names.
And they were able to confrim they do support glued names. For their testing, they took a four part name and stuck the first to second, second to third, third to fourth and verified they got the same "hit" every time.


That's good to know!
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#1631735 - 11/22/11 11:28 PM Re: OFAC filters - glued names - OCC looking at E.E.G.B
nnayak Offline
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My OFAC filter does Glue names(MaryJane), Spaced Names (M a r y j a n e), sounds like (marijame), spelled like (Mary Jan3), etc. Does yours do these?

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#1636593 - 12/07/11 08:03 PM Re: OFAC filters - glued names - OCC looking at nnayak
E.E.G.B Offline
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I noticed today that the SDN list search from OFAC's site doesn't recognize glued names.
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#1636608 - 12/07/11 08:03 PM Re: OFAC filters - glued names - OCC looking at E.E.G.B
rlcarey Online
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I don't believe that they use an algorithmic matching process.
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