When receiving two name matches on non-customer IAT originators (often matching one of the AKAs) and our risk assessment deems it appropriate, what form of due diligence are other banks doing in the same situation? Oftentimes, the name on the OFAC does not include an address, and we only have the address of the IAT originator with no other identifying information. Are you contacting the originator financial institution? We have tried contacting originator financial institutions on other OFAC matters and they were reluctant to speak with us. With no information to match it against on the OFAC, it would be pointless to call OFAC. I appreciate any feedback you might offer regarding this.

If it matches the data and we cannot find/obtain other information to clear it, we reject it until other information can be obtained - risk safe. Depends on 'how much' there is a match.

We had a similar situation a couple of weeks ago. It was a Paypal debit to our accountholder. I talked with an individual at OFAC and he said in situations where there isn't enough information to conclusively determine if it's false positive or true hit, there are three options.
1) Proceed as if it's a true match and follow the OFAC rules accordingly (blocking, setting up accounts, etc);
2) Proceed as if it's a definite false positive, document and process payment; or
3) Return the payment as a R16 as an abundance of caution to comply with government regulations.

He said that option 3 does not require notification to OFAC and that it's the most common response in cases where all resources have been exhausted and it just can't be determined conclusively.

We had a situation the exact same as the above; same information from OFAC as well, and also dealing with PayPal. The individual from OFAC told us to have our customer attempt to obtain the information from the individual they were dealing with; and also noted that they were well aware that 9 times out of 9 (not 10, that was put purposely) the two individuals have virtually no relationship and therefore the information cannot be obtained -- at which point we returned the payment as noted in item 3 above.

Best to err on the side of caution on these things, if you don't have sufficient information to make an informed decision regarding whether or not you have a true match or false positive, then I wouldn't process the payment. Let the customer get the information for you; after all, they're the ones that want that payment to be sent!

I am having a similar issue. The IAT originator's name is a positive match. However, we do have an address of China for the originator and the OFAC hit has an address in South Carolina. In this case, would it be okay to clear this since the address is clearly different or should we treat it like a true match since the name matches exact?

Previously I've been told by OFAC that a "true" hit requires a 100% match (name, address, other identifying info etc.). If you have a match to name only and the address info you have does not match then you have no hit.

I've been using the above as my SOP for the past couple years and haven't had any push back on it. Additionally, I like to go straight to the SDN website and go line by line with my search criteria and print off the results. For example, complete all fields (name, address, city, country,)>search>"no results found">Print page for documentation, Remove street address>perform search again>print, Remove city>perform search again>print etc. I also lower the confidence setting for any results from 100% to 85% to account for any misspellings or translation errors.

It's a bit of work but for the amount of potential hits we have it's not that bad.