When using bronID to screen for PEPs, Sanctions, and Watch List, fuzzy matching is employed. Fuzzy matching is a technique that allows for partial matches when comparing segments of text. This is necessary because the individuals or organisations being screened may not perfectly match the entries on the PEPs, Sanctions, and Watch Lists. For example, "John Citizen" might be a partial match for "Jon Citizen."
Here are the most common reasons why someone would match a PEPs or Sanctions list:
- The individual/organisation appears on a PEPs or Sanctions List.
- The submitted name is an alias.
- The individual is a relative or associate of someone who appears on a PEPs or Sanctions List.
- The individual/organisation is associated with an entity that appears on a PEPs or Sanctions List.
- The individual/organisation has the same or a similar name to an individual/organisation that appears on a PEPs or Sanctions List.
If bronID has flagged that an individual or organisation is on a PEPs, Sanctions, or Watch List, the first thing you must do is check for false positives. To check for false positives in bronID, follow these steps:
- Open the list accordion by clicking on the down arrow.
- Read the description that bronID returned for every list that has been matched. Here you can compare parameters other than the name, such as the date of birth, middle name, or the place of residence/incorporation, to assess if the matched individual or organisation is the same as your customer.
Review and document false positives
To determine if a match on a PEP (Politically Exposed Person) or Sanctions list is a false positive, you need to conduct a detailed comparison between the information of the individual in question and the details listed. Here's a step-by-step process:
1. Initial Flagging
Identify what aspect of the individual’s profile triggered the match. Common triggers include similar or identical names, dates of birth, or addresses.
2. Gather Comprehensive Information
Collect all available information about the individual from your internal records and obtain any additional information that can help in the identification process, such as middle names, aliases, or different spelling variations.
3. Compare Key Identifiers
- Name Matching: Compare the full name of the individual with the name on the list, paying attention to full names, initials, and any aliases.
- Date of Birth: Check if the date of birth matches with the one on the list.
- Address and Geographical Information: Verify if the individual's current and past addresses align with those on the list.
- National Identification Numbers: Compare social security numbers, tax identification numbers, or any other national identification numbers.
- Photographic Identification: Visually compare any available photos.
4. Analyse Secondary Identifiers
Evaluate employment history, educational background, and other personal data points to distinguish individuals. Check for connections or associations with known PEPs or sanctioned entities.
5. Consider Contextual Information
Evaluate if there's any plausible reason for the individual to be on a PEP or Sanctions list, such as their occupation or political connections.
6. Consult Additional Databases
Check other databases or sanction lists for more comprehensive data or different data points for a broader comparison.
7. Document Discrepancies and Similarities
Keep a detailed record of all the points of comparison, noting where information matches and where it does not. Document any uncertainty or areas where information is incomplete.
8. Expert Review
Have a compliance officer or someone with expertise in identity verification review the findings. They may identify nuances or additional checks that could clarify the situation.
9. Make a Decision
Based on the collected evidence, determine if the match is a false positive or if further investigation is needed. Consider reaching out to the individual for clarification if still uncertain.
10. Update Records and Systems
If a false positive is confirmed, update your systems to prevent a similar match in the future. Adjust matching algorithms or criteria if necessary.
Each step should be thoroughly documented for audit purposes and compliance with regulatory requirements. Once you have made a decision and resolved that a particular match is a false positive, you can lower the IDV (Identity Verification) risk associated with the KYC (Know Your Customer) or KYB (Know Your Business) processes. This can be documented by attaching all supporting evidence and providing a clear rationale for deeming the match to be a false positive.