RUSSIA SANCTIONS – MINISTRY OF FINANCE OF THE RUSSIAN FEDERATION – NAME SCREENING TESTING GUIDE
🚩#4 Russia Sanctions Testing Guide #4🚩
🔎Does your Filter Detect Variations for “MINISTRY OF FINANCE OF THE RUSSIAN FEDERATION”? OFAC’s does, with scores ranging from 96 to 100. 👊💥Test Your Filter and Verify💥👊
👀 Yesterday, additional names were added to the U.S. Department of the Treasury OFAC list. In reviewing the OFAC entry for “MINISTRY OF FINANCE OF THE RUSSIAN FEDERATION”, I noticed that no AKAs were provided (strong or weak).
Given the length of the entity’s name, its known online name (aliases), the likelihood for its long name being abbreviated, and the fact there were zero weak AKAs provided, 🚦 non-detection of its abbreviated or simple name variations name becomes a gray area for sophisticated institutions bearing greater responsibilities as seen in recent OFAC settlements.
📝HOW TO USE THE GUIDE: Search for the name variations found online, their abbreviated forms, and some that come to mind:
♦️ “Ministry of Finance for the Russian Federation”,
♦️ “Russian Ministry of Finance”,
♦️ “Finance Ministry of Russia”,
♦️ “Ministry of Finance RU”
♦️ “MINFIN”,
♦️ “MOFOTRF”
🚩NON-DETECTION REMEDIATION: If not generating a match for a variation you believe merits detection, contact your screening vendor to augment screening detection. If your vendor is unable to anything in the short term, add the missed name variation(s) to your in-house screening list as a stop gap. (Always test to understand the impacts of augmenting your list.)
👀 REMEMBER FILTERS AREN’T LIKE HUMANS: Screening filters are not intuitive, they don’t “see” what you and I “see” and they don’t have common sense.
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📌 DISCLAIMER:
: These test scenarios don’t focus on typos, testing should always consider fat finger, transliteration, translation, abbreviations, and/or typos.
