A name match: how to establish whether it is your client

Start with the original entry

Open the publisher’s original entry and record its identifier. Check all names, former names and transliterations. Different Latin spellings may refer to the same person, while a short match may fit several people. Distinguish a company’s brand, legal name, abbreviation and former name. Do not rely solely on a vendor’s shortened result card.

UN entries may include alternative dates of birth, birthplace, nationality, documents and addresses, with distinctions in alias quality. A missing field means information is unavailable, not that your client differs. OFAC name searching uses fuzzy logic. A score represents the tool’s similarity assessment, not the percentage probability of legally confirmed identity.

Compare a combination of evidence

Create a comparison of client and list data: match, conflict or unknown. Birth dates or registration numbers often distinguish more reliably than a city of residence. Addresses may be old, nationalities multiple and listed birth dates approximate. Explain each conflict’s significance: different numbers for the same document type do not alone reliably exclude identity, since documents can change.

Request only information needed to resolve the actual uncertainty and verify its origin. The record should let another employee understand why the alert was closed. For complex structures or incomplete identifiers, assign further investigation. Distinguish operational withholding of approval from statutory asset freezing and suspension of an order; their conditions differ.

Closing an alert requires reasons

Support an excluded match with material verified differences. Confirmed identity still requires assessment of the measures and their applicability. Do not label an unresolved case clear because an internal deadline elapsed. Obtain accountable decision-making before the transaction and statutory escalation where required. Do not publish the conclusion or accuse the client of an offence without evidence.

Practical comparison of one match

Consider a client sharing a common name with a listed person. The list gives an approximate birth year, an old address and an alias; the client provides a current identity document. Record each item separately. A different current address need not exclude identity. The document may help with birth information, but an approximate listed date requires further distinguishing evidence. Closure must reflect the combined evidence’s significance.

You can retain an internal record of a previously excluded match for repeated results. It must not become a permanent screening exemption. Reassess whether the original reason still applies after a new record, alias or identifier change. Link the historical decision to the exact identifier and source version so exclusion of one individual is not transferred to another with the same name.