FinCEN CDD Final Rule Tightens Screws on Name-Screening

The final version of FinCEN’s CDD requirements for financial institutions have now been issued, and they are already the subject of much discussion among AML/KYC practitioners.  Much of this discussion has to date been devoted to risk models and risk-containment procedures that implement these models. Largely overlooked in the rush …

Continue reading

Churchill, Names and “Anglo Privilege”

In April of 1945, as the war in Europe was in its final desperate phase, Winston Churchill took a momentary break from directing the entire British military and political effort in order to dash off a quick note to some (thankfully) nameless low-level official in the Foreign Office who had …

Continue reading

Are You Storing Your AML/KYC Data in the Bed of Procrustes?

There’s no substitute for knowing… In previous posts, I’ve attempted to convey some sense of the linguistic and cultural diversity that personal names exhibit, especially when these names are converted from other writing systems and social contexts into the Roman (A-Z) alphabet and the naming system that predominates in the …

Continue reading

KYD In Action: Names from the Islamic World

In this post, I’d like to provide an overview of the ways Islamic names encountered in AML/KYC contexts can differ from familiar Anglo/European names. I will emphasize those aspects that cause complications both for automated processing (searching and matching) and for human interpretations.  In several previous posts, I have covered …

Continue reading

Know Your Data: OFAC and Hispanic Names

Why KYD Matters In my previous post, there was a chart that shows the extent to which a relatively small number of name-models predominate in OFAC SDN data. My ultimate purpose in providing that graphic was two-fold: To show that reliance on mediocre, Anglo-centric name-screening techniques such as SOUNDEX and …

Continue reading

From the headlines to your AML/KYC system: the strange case of Mr. Wu

Breaking News That You Can Use Recently, all the major news channels carried a high-profile story about a Chinese businessman, Ng Lap Seng, who was arrested by the FBI for financial crimes, on the very same day that the Chinese President, Xi Jinping, arrived in Seattle, to begin his U.S. …

Continue reading