Bigger fish to fry? Issues with OFAC SLSA (continued)

The Helpful (and Thrifty) Fisherman

Indulge me for a little bit, and let me stay with my fish story.

So, you’ve headed to a hidden-away little lake in the deep north woods where pals have told you there are some trophy-sized bass to be caught. When you get there, you see a weathered old angler on the shore whose live creel is already bulging with fat largemouth bass, just like the ones that you’re hoping to catch. You approach him, and ask him what bait he is using and where the fish are biting that day.

He seems friendly enough, and he soon launches into a long-winded discussion about ways to tell a largemouth from a smallmouth, a bass from a crappie or a sunfish. You wait him out, then ask again: how do I catch some of these huge largemouth bass, like the ones you have? But he just drones on about all the different species of game-fish that he has caught in the lake. He smiles and shows you his crude bamboo fishing pole and a safety-pin that he has fashioned into a hook. “This always works great for me!” he says proudly. “No need to spend your money on one of those fancy imported graphite gizmos. Here — take my spare rod.”

You take the bamboo rig, attach the safety pin, and go to a near-by spot of your own. Convinced that you will start reeling in the big ones before too long, you work the lake for three or four hours. All the while, the old angler is looking on, smiling his encouragement.

The afternoon wears on, and the sun starts getting low. Then you realize that you haven’t had even a single nibble the entire time. You also realize that the old angler has not landed a fish in the entire time you’ve been there. You walk back over to the old guy, and ask once again about his creel full of fish. “Oh these? My buddy Joe got these earlier, and asked me to bring them back to town for him. I have no idea what kind of fishing rig he was using, though. Nice fish, eh?”

Suddenly, you feel very foolish standing there with a kid’s fishing pole in your hands and a very empty creel to go with it. So you ask “Say, about how many fish like those big ones have you caught here in this lake?” He scratches his head, then says with a sheepish grin “None, I guess. But I sure do like my pole — I made it myself!” And you realize that you might have been clued in by the odd way that the old angler responded to your first question — how do I catch big fish like those in the creel?

And the Moral of the Story Is…

Thanks for staying with me through the fish story. It was the best way I know to make a rather abstruse point about precision and recall when matching names for AML/KYC compliance. And, like many good stories, this one ends with a moral: if you want to catch the big ones (in fact, all of the big ones), you probably need to ask a true fisherman what equipment works best, and you need to see the results that equipment has delivered for that fisherman.

Just because someone tells you there are plenty of big fish in the pond, and just because a fisherman is proud of his home-made fishing rig, that doesn’t mean you’ll get much help in catching your share. And if most of the advice that you are offered has to do with knowing whether or not you have caught the right fish, that’s probably even less helpful.

Better yet, if someone offers to do the fishing for you, you might want to see if the rig being used is right for the kind of fish you’re trying to catch.

At the risk of pushing the fishing metaphor beyond its reasonable limits, I want to say why I think that there actually are some times when a fancy graphite rod may be a better idea than a bamboo pole and a safety pin. Like when the survival of your business depends on it, for example.

But I’ll save that discussion for my next post…

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