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#5521 - 10/15/01 01:51 PM OFAC Suspects
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
We had our data processing company run our full customer file against the OFAC list last week and they gave us a list of 70 "OFAC Suspects", including about a dozen boy scout troops. In the past, we have had one or two "suspects" that were easily cleared. The problem I have run into with this list of 70 people and companies is that there are no exact matches, and most are not even close to any of the names or AKA's on the OFAC list. Usually I will use the online tool from Bridger to enter these names and if they are close, it will come up with an alert to let you know who it matches up with. The majority of these names don't come up. How do you clear these customers if you have no idea why they appear as suspects? Any help that you can give me would be greatly appreciated.
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General Discussion
#5522 - 10/15/01 02:00 PM Re: OFAC Suspects
Anonymous
Unregistered

I know our system will show a match if any part of a word is in the name or address. Example: Miranda = iran
Maybe this is why these names have shown up on your list. I would check for any partial words within the name or address...maybe this will help.

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#5523 - 10/15/01 02:46 PM Re: OFAC Suspects
La. Lady Offline
Diamond Poster
La. Lady
Joined: May 2001
Posts: 1,873
Our system allows for certification of those accounts that appear on the "hit" list that may be (as put earlier) any form of the word. Such as Miranda = Iran.

Perhaps there is some type of function that your system has to allow for such certifications. If not, maybe you could talk to them about enhancements.

Good luck!

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#5524 - 10/15/01 03:36 PM Re: OFAC Suspects
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
I agree, sometimes just a combination of some letters in the name can trigger it to be on the suspect list. In fact, many of our employees and stockholders appeared on the list. Our system (Jack Henry) also allows for "certification". If your system allows this it will be much easier on you the next time you run the matches.

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#5525 - 10/16/01 04:02 AM Re: OFAC Suspects
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
A question for Jack Henry users. In reviewing documentation for Release 11, I came across a reference about OFAC verification of ACH files. I knew we were getting some expanded OFAC features, but the documentation sounds as if it has been out there for ACHs already.

1)Does anyone know if we have had OFAC ACH verification capabilities prior to Release 11?
2)How can we integrate this into our wire transfer room?

Thanks for your help. I really appreciate the resources provided on this site.

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#5526 - 10/15/01 07:34 PM Re: OFAC Suspects
PABanker Offline
Gold Star
PABanker
Joined: Dec 2000
Posts: 491
Blue Ball, PA 17506
Yes, we had OFAC ACH verfication before Release 11 but only on incoming ACH.

We handle our wires by entering the information manually into the OFAC inquiry screen. Our reasoning is that the wire option with Jack Henry does not meet all the OFAC requirements.

If you do find a method for the wire that meets all the OFAC requirements, please inform us of the how to's. Thanks.


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#5527 - 10/15/01 08:04 PM Re: OFAC Suspects
cboynefirstgabank Offline
100 Club
cboynefirstgabank
Joined: Apr 2001
Posts: 147
brunswick ga usa
We use The Bankers Bank out of Atlanta to process our wires. They run all of our outgoing wires through an OFAC list and let us know if we have a hit on the beneficiary of the wire. (We do not process wires for non customers, and use Jack Henry which checks all of our existing customers) I do not know what kind of program The Bankers Bank is using or if it would be cost effective for a smaller bank?

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#5528 - 10/16/01 02:54 PM Re: OFAC Suspects
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
I would like to hear more about options available for running our customer base against the OFAC list. What are the pros and cons of purchasing software vs using a 3rd party to screen our customer base. What kind of costs should I expect to encounter? Any recommendations of particular software or 3rd parties would be appreciated.

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#5529 - 10/16/01 11:47 PM Re: OFAC Suspects
matthewcompliance Offline
Member
Joined: Jul 2001
Posts: 59
ventura,CA,USA

By the end of this week we will have the OFAC list in database for one search will check all names and aliases. We will be selling this on an annual subscription basis at only $399 P.A. (we are recouping loss not trading off the back of Sept. 11).

We can also run Interpol searches for subscribers at no extra cost.

We will also have the Excluded parties in database form inclusive in this price.

This tool is primarily aimed at small banks where economics make a screen system ineffective and where they don't want to run the risk of waiting for third party screening.

More information is available from Total Compliance Group Inc. 805-642-6250.


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#5530 - 10/18/01 08:29 PM Re: OFAC Suspects
prosperity Offline
Member
prosperity
Joined: Oct 2001
Posts: 82
Houston, TX
Brenda,

We're a JHA client also Do you have more information about the ACH verification capability in the OFAC module. I couldn't find anything in Chapter 42 of the manual.

wandaj@prosperitybanktx.com


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#5531 - 10/19/01 03:45 PM Re: OFAC Suspects
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Wanda - I don't have a JHA Release 11 manual yet, so I am relying on information contained in the Release 11 Enhancements. It is my understanding that the system will match ACH batches to OFAC and notify the operator a match exists. The operator will have option to print OFAC Activity Report CF7590 and continue with ACH batch origination. The report will be distributed to OFAC compliance officer next day.

It's not a perfect world since the batch will already have been released, but I think it is the best we can do right now. I am going to try to work with our data processing area to see if we can prescreen batches for review prior to release. We would certainly have to do a better job of making sure our customers originating ACHs get us their files on time for this to work.

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#5532 - 10/19/01 03:47 PM Re: OFAC Suspects
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
The instructions were in Capter 42 of our manual. (Rel 2.11)

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#5533 - 10/19/01 06:53 PM Re: OFAC Suspects
Mary Beth Guard Offline
Platinum Poster
Mary Beth Guard
Joined: Oct 2000
Posts: 797
Oklahoma City, OK
There were several questions in this thread and other OFAC-related threads about OFAC software. Innovative Systems helps make BankersOnline possible by advertising with us. I asked for their expertise in responding to these software-related inquiries. Their helpful response is below. An article they've contributed on "How to Select OFAC Software" will also be up on the site beginning Monday.

The following info is from Chuck Schardong,
Senior Product Manager, Innovative Systems, Inc.:
Many of the matching concerns and issues expressed in the BankersOnline OFAC threads seem to revolve around three key areas: quality, reliability and the detail of the results being generated from the various OFAC software systems. All are very important concerns.

Matching Methodologies
There are several matching methodologies used in the marketplace today by OFAC solution providers -- including basic matching algorithms such as string-comparison, key-based and weighted-field matching technologies. In my opinion, the issues being discussed are consistent with known constraints inherent to these matching methodologies.

For example, the Miranda=iran case is a potential problem of string-comparison algorithms, because this technique cannot provide the true context for the data being matched. Likewise, not being able to specifically demonstrate why two records matched within a given score/filter, such as the boy scout records, is a potential problem with weighted-field technologies. The logic behind these technologies tend to promote an increase in false-positive match rates which, in turn, creates additional manual review work for the compliance staff or brings to question the reliability and capability of the products.

Parsing Data Also Important
It should also be noted that matching shortcomings may be compounded by the parsing routines used by the basic matching algorithms. Parsing routines are the foundation for choosing the data elements which will be compared by the matching engines. Since match results can be impacted by poor data quality, parsing routines should be able to address existing issues in the data to more accurately choose the most appropriate data for matching. Parsers should also be able to decipher and ignore noise words in the customer data -- for example, relationship terms such as UGMA, MINOR, TRUSTEE and ITF, as well as name appendages such as JR, SR and PHD - that could impact match results. Minimizing the impacts of parser-related errors can greatly reduce the amount of false-positive matches.

How to Maximize Matching Accuracy
The key to maximizing the accuracy, reliability and usability of matching products is to combine a more sophisticated, heuristic matching algorithm with knowledge bases of words and patterns that guide the parsing process. This combination permits accurate matching in spite of misspellings, transpositions, missing information, and other variations and anomalies. It will prevent, for example, an individual's name from being incorrectly compared to a street or country.

What to Look For
For accurate, reliable OFAC matching - or any customer data matching, for that matter - the software you select should include:
Matching methodology that minimizes or eliminates false positive matches without causing missed matches
Output that clearly identifies how and why records were matched
Flexibility to match on both name and address, as well as name only, or address only
Opportunity for users to specify their own unique matching criteria and thresholds.
Adequate parsing capability - because matching technologies are often only as good as the parsers which help determine the fields to be compared
Accurate and consistent matching in both online and batch environments
And, to better justify the cost from a business standpoint, the software should be able to be used not just for OFAC compliance, but wherever customer matching is required

For more information on OFAC compliance, or for a copy of Innovative's White Paper on Data Matching Architecture which better outlines the advantages and disadvantages of the available matching methodologies, please visit our web site or contact us at 800.622.6390.



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