As a matter of course OFAC weak aliases are typically excluded from screening. And for good reason. OFAC’s own guidance recognises that it is not realistic to screen for names of such low quality either by the fact that they are very short or very generic in nature:
“OFAC’s regulations do not explicitly require any specific screening regime. Financial institutions and others must make screening choices based on their circumstances and compliance approach. As a general matter, though, OFAC does not expect that persons will screen for weak AKAs, but expects that such AKAs may be used to help determine whether a “hit” arising from other information is accurate.”[1]
But it can seem like other names on the SDN list should qualify for weak status, so what is the logic behind the classification?
OFAC offers this explanation:
“…OFAC has instituted procedures that attempt to make this qualitative review of aliases as objective as possible… Names were evaluated using the following criteria:
1. Character length (shorter strings were assumed to be less effective in a screening environment than longer strings);
2. The presence of numbers in an alias (digits 0-9);
3. The presence of common words that are generally considered to constitute a nickname (example: Ahmed the Tall);
4. References in the alias to geographic locations (example: Ahmed the Sudanese);
5. The presence of very common prefixes in a name where the prefix was one of only two strings in a name (example: Mr. Smith).”
Let’s have a look at the SDN list and see if we can follow the above criteria. First, let’s look at the SDN entries designated as individuals with under ten characters:
The number of prime or strong alias names certainly tails off significantly as the number of characters are reduced, but there are still a few entries that are less than five characters in length:
However, each of these has two words, so perhaps the “short names” are really one-word short names? These are all the one word strong alias names (there are no one word prime names):
OK, so for rule #1, perhaps we should interpret short to mean consisting of one word of less than six characters? What about the other rules? These are the 21 individual names containing a numerical digit:
They are all classified as weak so rule #2 seems to have been applied faithfully.
How about Rules #3-5? What should we look for here? Maybe we can find a hint by looking at the frequency of words appearing in the weak aliases:
OK, a good start may be to look for names containing “the”:
Indeed, these are all classified as weak. Many of them conform to rule #4, containing geographic locations. How about names containing “don”:
Again, this seems reasonable – “Don” followed by a single word is classified as weak. The occurrence of “Don” in the two non-weak names is clearly part of the family name. What about abu (meaning “father of”)? With 370 occurrences in the weaks you might expect that this would be an example of rule #5. However, in reality there are many counter-examples:
These don’t appear to be substantially different to the weak counterparts – here’s a small sample:
Clearly a name consisting of “Abu” followed by a single word is not considered to be an example of rule #5. Let’s have another look at the most common prefixes and stick to two word names:
So it looks like prefixes such as “al”, “la” and “el” (all are the definite article) are classified as weak when combined with one additional word, but abu (and its variant “abou”) and haji (“one who has completed the Hajj to Mecca”) are not.
In conclusion, there does appear to be reasonable consistency in the qualification of weak alias for individual names. The rules stated by OFAC can be interpreted roughly as follows:
- Single word names of less than six characters
- Presence of numbers
- Common words considered to be nicknames (e.g. Don)
- Names containing geographic locations (e.g. Abu Rawaha the Italian)
- Two word names with low value prefixes (e.g. al, el, la, the)
However, there are criteria that are not considered enough to class as weak (but perhaps should be):
- Two word names of less than six characters (e.g. Bin XU, Na CHU)
- Two word names with other common prefixes (e.g. Abu AISHA, Haji BANDO)
And what about Entity names? How do the rules apply to them? We will follow up on this question in part 2 of this series.
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[1] https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1646
