Volume 2, Issue 19

Posted on 9/24/2014

OFAC Sanctions List Search Tool

As of June 9, 2014, OFAC's SDN Search tool has been renamed Sanctions List Search.  The improved search tool employs fuzzy logic on its name search field to look for potential matches on both the Specially Designated Nationals (SDN) List and the Foreign Sanctions Evaders (FSE) List. To access the Sanctions List Search,click here


More information on this new tool can be found in the frequently asked questions provided below.


1) How does Sanctions List Search work?

In addition to returning results that are exact matches (when the match threshold slider bar is set to 100%), Sanctions List Search can also provide a broader set of results using fuzzy logic. This logic uses character and string matching as well as phonetic matching. Only the name field of Sanctions List Search invokes fuzzy logic when the tool is run. The other fields on the tool use character matching logic.   Please click here for more information on what a true SDN or FSE match is.


2) What does the Sanctions List Search Score mean?

The score field indicates the similarity between the name entered and resulting matches on the SDN and/or FSE Lists. It is calculated using two matching logic algorithms: one based upon phonetics, and a second based upon the similarity of the characters in the two strings. A score of 100 indicates an exact match, while lower scores indicate potential matches.


3) How do I use the Minimum Name Score field and score slider bar?

The minimum name score field limits the number of names returned by the search. A value of 100 will return only names that exactly match the characters entered into the name field. A value of 50 will return all names that are deemed to be 50% similar based upon the matching logic of the search tool. By lowering the match threshold the system will return a broader result set.


4) How is the Score calculated?

Sanctions List search uses two matching logic algorithms and two matching logic techniques to calculate the score. The two algorithms are Jaro-Winkler, a string difference algorithm, and Soundex, a phonetic algorithm. The first technique involves using the Jaro-Winkler algorithm to compare the entire name string entered against full name strings of SDN and FSE entries. The second technique involves splitting the name string entered into multiple name parts (for example, John Doe would be split into two name parts). Each name part is then compared to name parts on the SDN and FSE lists using the Jaro-Winkler and Soundex algorithms. The search calculates a score for each name part entered, and a composite score for all name parts entered. Sanctions List Search uses both techniques each time the search is run and returns the higher of the two scores in the Score column.


5) Does OFAC recommend a specific match threshold score?

OFAC cannot make such a recommendation because each search has its own unique set of facts surrounding it. Users of Sanctions List Search must make their own match threshold determinations based upon their own internal risk assessments and established compliance practices.


6) What fields influence the score?

Only the name field influences the score.


7) What fields use fuzzy logic?

Only the name field uses the fuzzy searching logic. 


8) When conducting a search using the ID field, does Sanctions List Search account for variations in non-alphanumeric characters?

At present, Sanctions List Search's ID field uses exact character matching to provide users with a result. In order to receive the broadest number of results, users should conduct ID field searches both with and without any non-alphanumeric characters. An upcoming update to Sanctions List Search will allow for searching of the ID field regardless of whether or not non-alphanumeric characters are included.     


9) Who may use Sanctions List Search? Can we configure our automated system to utilize Sanctions List Search on a continual basis?

Sanctions List Search is a free tool provided by OFAC to assist the public in complying with sanctions programs. It is intended to be used by individual users that are looking for potential matches on the SDN and FSE list. It should not be utilized by automated systems that are configured to continually run searches through the tool. For a copy of files that can be easily interpreted by automated systems and software programs, please see the list of XML, CSV, PIP, DEL, and FF files on the SDN and FSE pages. 


10) Does Sanctions List Search look for potential matches on all of the various sanctions lists that OFAC has published on its website?

Sanctions List Search will look for and return potential matches from the SDN and FSE Lists only. The user can look under the List column to see which list(s) a potential match is on.     

Office of Foreign Assets and Control Webinar
Your OFAC compliance program will be examined with BSA. The connection between BSA and OFAC begins with safety and soundness. How will your OFAC program do? Are you ready to answer some tough examination questions? Join Debbie Crawford on November 7th to review what should be in an OFAC Compliance Program. She will discuss the officer responsible for OFAC and how to go from a "hit" to a "match" and what to do in the action steps in between. You will learn how OFAC impacts BSA, ACH and other issues in your organization. For more information or to registration for this webinar, click here

Volume 2, Issue 18

Posted on 9/4/2014

Inherited IRAs May Not Be Protected!

In a recent court case, when petitioners filed for Chapter 7 bankruptcy, they sought to exclude roughly $300,000 in an inherited individual retirement account (IRA) from the bankruptcy estate using the "retirement funds" exemption. See 11 U. S. C. § 522(b)(3)(C). The Bankruptcy Court concluded that an inherited IRA does not share the same characteristics as a traditional IRA and disallowed the exemption. The District Court reversed, explaining that the exemption covers any account in which the funds were originally accumulated for retirement purposes. The Seventh Circuit disagreed and reversed the District Court. 


Funds held in inherited IRA accounts are not "retirement funds" within the meaning of 11 11 U.S.C. §522(b)(3)(c) and therefore not exempt from the bankruptcy estate. 


Join Debbie Crawford on September 9th to learn more about inherited IRAs and death distributions. In this program, she will take you from the death of the account holder to the beneficiary. She will look at detailed options for spouse and non-spouse beneficiaries. If you have struggled with these in the past, you may want to know how to set up the file, report it properly to the IRS and give clear instruction to the account holder on his or her options. Many errors occur during the transfer of the IRA to the beneficiary and can cause reporting liabilities, double taxation and 50% penalties to the account holders who inherit these accounts. This is a comprehensive approach to death distributions on an IRA that you won't want to miss.For more information or to register, click here


September is National Cyber Security Awareness Month

The Internet is part of everyone's life, every day. We use the Internet at work, home, for enjoyment, and to connect with those close to us.

However, being constantly connected brings increased risk of theft, fraud, and abuse. No country, industry, community, or individual is immune to cyber risks. As a nation, we face constant cyber threats against our critical infrastructure and economy. As individuals, cybersecurity risks can threaten our finances, identity, and privacy. Since our way of life depends on critical infrastructure and the digital technology that operates it, cybersecurity is one of our country's most important national security priorities, and we each have a role to play-cybersecurity is a shared responsibility.


Bankers eCampus has a Security Series that is taught by Susan Wind. You can purchase one or all parts of the series. You will gain knowledge on how to keep you, your employees, account holders and financial institutions safe! For more information, click here.  


FinCEN Issues Advisory to US Financial Institutions on Promoting a Culture of Compliance

BSA/AML shortcomings have triggered recent civil and criminal enforcement actions - FinCEN seeks to highlight the importance of a strong culture of BSA/AML compliance for senior management, leadership and owners of all financial institutions subject to FinCEN's regulations regardless of size or industry sector. To read this advisory in its entirety, click here


Bankers eCampus has a complete BSA Series. Taught by Debbie Crawford, the thirteen part BSA Officer Training Series can be used as a guide to get the most complete training and education experience on important BSA topics. For more information or to purchase any part of the series, click here.  


Virtual Currencies Pose Risk

The Consumer Financial Protection Bureau (CFPB) issued a consumer advisory warning consumers about the risks of virtual currencies such as Bitcoin. The CFPB advises consumers to be aware of potential issues with virtual currencies such as unclear costs, volatile exchange rates, the threat of hacking and scams, and that companies may not offer help or refunds for lost or stolen funds. The CFPB also announced that consumers who encounter a problem with a virtual currency product or service can now submit a complaint with the Bureau. For more information or to read the advisory, click here

Do you have a question or topic that you would like to see addressed in our monthly newsletter? If so, email us and let us know. Send questions and/or topic suggestions to info@bankersecampus.com.