Weak Aliases

If you are calling about a wire transfer or other "live" transaction:

Step 1. Is the "hit" or "match" against OFAC's Specially Designated Nationals (SDN) list, one of its other sanctions lists, or targeted countries, or is it "hitting" for some other reason (i.e., "Control List" or "PEP," "CIA," "Non-Cooperative Countries and Territories," "Canadian Consolidated List (OSFI)," "World Bank Debarred Parties," "Blocked Officials File," or "government official of a designated country"), or can you not tell what the "hit" is?

• If it's hitting against OFAC's SDN list, one of its other sanctions lists, or targeted countries, continue to 2 below.
• If it's hitting for some other reason, you should contact the "keeper" of whichever other list the match is hitting against. For questions about:
• The Denied Persons List and the Entities List, please contact the Bureau of Industry and Security at the U.S. Department of Commerce at 202-482-4811.
• The FBI's Most Wanted List or any other FBI-issued watch list, please contact the Federal Bureau of Investigation (Contact Us — FBI).
• The Debarred Parties list, please contact the Directorate of Defense Trade Controls at the U.S. Department of State, 202-663-1282.
• The Bank Secrecy Act and the USA PATRIOT Act, please contact the Financial Crimes Enforcement Network (FinCEN), 1-800-949-2732.
• If you are unsure whom to contact, please contact your screening software provider which told you there was a "hit."
• If you can't tell what the "hit" is, you should contact your screening software provider which told you there was a "hit."

Step 2. Now that you've established that the hit is against one of OFAC's sanctions lists or targeted countries, you must evaluate the quality of the hit. Compare the name in your transactions with the name on the sanctions list. Is the name in your transaction an individual while the name on the sanctions list is a vessel, organization or company (or vice-versa)?

• If yes, you do not have a valid match.*
• If no, please continue to 3 below.

Step 3. How much of the listed entry's name is matching against the name in your transaction? Is just one of two or more names matching (i.e., just the last name)?

• If yes, you do not have a valid match.*
• If no, please continue to 4 below.

Step 4. Compare the complete sanctions list entry with all of the information you have on the matching name in your transaction. An entry often will have, for example, a full name, address, nationality, passport, tax ID or cedula number, place of birth, date of birth, former names and aliases. Are you missing a lot of this information for the name in your transaction?

• If yes, go back and get more information and then compare your complete information against the entry.
• If no, please continue to 5 below.

Step 5. Are there a number of similarities or exact matches?

• If yes, please contact the compliance hotline.
• If no, you do not have a valid match.*

If you are calling about an account:

Step 1. Is the "hit" or "match" against OFAC's SDN list, one of OFAC's other sanctions lists or targeted countries, or is it "hitting" for some other reason (i.e., "Control List" or "PEP," "CIA," "Non-Cooperative Countries and Territories," "Canadian Consolidated List (OSFI)," "World Bank Debarred Parties," or "government official of a designated country"), or can you not tell what the "hit" is?

• If it's hitting against one of OFAC's sanctions lists or targeted countries, continue to 2 below.
• If it's hitting for some other reason, you should contact the "keeper" of whichever other list the match is hitting against. For questions about:
• The Denied Persons List and the Entities List, please contact the Bureau of Industry and Security at the U.S. Department of Commerce at 202-482-4811.
• The FBI's Most Wanted List or any other FBI-issued watch list, please contact the Federal Bureau of Investigation (Contact Us — FBI).
• The Debarred Parties list, please contact the Directorate of Defense Trade Controls at the U.S. Department of State, 202-663-1282.
• The Bank Secrecy Act and the USA PATRIOT Act, please contact the Financial Crimes Enforcement Network (FinCEN), 1-800-949-2732.
• If you are unsure whom to contact, you should contact your screening software provider which told you there was a "hit."
• If you can't tell what the "hit" is, you should contact your screening software provider which told you there was a "hit."

Step 2. Now that you've established that the hit is against one of OFAC's sanctions lists or targeted countries, you must evaluate the quality of the hit. Compare the name of your customer with the name on the sanctions list. Is the name of your customer an individual while the name on the sanctions list is a vessel, organization or company (or vice-versa)?

• If yes, you do not have a valid match.*
• If no, please continue to 3 below.

Step 3. How much of the listed entry's name is matching against the name of your account holder? Is just one of two or more names matching (i.e., just the last name)?

• If yes, you do not have a valid match.*
• If no, please continue to 4 below.

Step 4. Compare the complete entry with all of the information you have on the matching name of your account holder. An entry often will have, for example, a full name, address, nationality, passport, tax ID or cedula number, place of birth, date of birth, former names and aliases. Are you missing a lot of this information for the name of your account holder?

• If yes, go back and get more information and then compare your complete information against the entry.
• If no, please continue to 5 below.

Step 5. Are there a number of similarities or exact matches?

• If yes, please contact the compliance hotline.
• If no, you do not have a valid match.*

* If you have reason to know or believe that processing this transfer or operating this account would violate any of the Regulations, you must call the hotline and explain this knowledge or belief.

Strong and Weak Aliases

For additional information regarding strong and weak aliases on OFAC's sanctions lists, please see the Weak Aliases following topic.

A "weak AKA" is a term for a relatively broad or generic alias that may generate a large volume of false hits when such names are run through a computer-based screening system.  OFAC includes these AKAs because, based on information available to it, the sanctions targets refer to themselves, or are referred to, by these names. As a result, these AKAs may be useful for identification purposes, particularly in confirming a possible "hit" or "match" triggered by other identifier information. Realizing, however, the large number of false hits that these names may generate, OFAC qualitatively distinguishes them from other AKAs by designating them as weak. OFAC has instituted procedures that attempt to make this qualitative review of aliases as objective as possible. Before issuing this updated guidance, OFAC conducted a review of all aliases on the Specially Designated Nationals (SDN) list. Each SDN alias was run through a computer program that evaluated the potential of an alias to produce false positives in an automated screening environment. 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).

Aliases that met one or more of the above criteria were flagged for human review. OFAC subject matter experts then reviewed each of the automated recommendations and made final decisions on the flagging of each alias.

OFAC intends to use these procedures to evaluate all new aliases added to its sanctions lists.

Weak AKAs appear differently depending on which file format of the sanctions list is being utilized.

In the TXT and PDF versions of the Specially Designated Nationals (SDN) or other sanctions lists, weak AKAs are encapsulated in double-quotes within the AKA listing:

ALLANE, Hacene (a.k.a. ABDELHAY, al-Sheikh; a.k.a. AHCENE, Cheib; a.k.a. "ABU AL-FOUTOUH"; a.k.a. "BOULAHIA"; a.k.a. "HASSAN THE OLD"); DOB 17 Jan 1941; POB El Menea, Algeria (individual) [SDGT]

In the DEL, FF, PIP, and CSV file formats, weak AKAs are listed in the Remarks field (found at the end of the record) of the primary name file. In these formats, weak AKAs are bracketed by quotation marks. Please see the data specification documents for more information on the SDN and Consolidated lists.

SDN List Data Specifications: https://ofac.treasury.gov/system/files/126/dat_spec.txt
Consolidated List Data Specifications: https://www.treasury.gov/ofac/downloads/consolidated/cons_dat_spec.txt
8219 @"ALLANE, Hacene"@"individual"@"SDGT"@-0- @-0- @-0- @-0- @-0- @-0-@-0- @"DOB 17 Jan 1941; POB El Menea, Algeria; a.k.a. 'ABU AL-FOUTOUH'; a.k.a. 'BOULAHIA'; a.k.a. 'HASSAN THE OLD'."

In the legacy XML version of OFAC's sanctions lists, there is a Type element for each AKA.  The Type can either be 'weak' or 'strong' (see the XML SDN and Consolidated List Schemas (XSD files) at: https://ofac.treasury.gov/system/files/126/sdn.xsd and https://www.treasury.gov/ofac/downloads/consolidated/consolidated.xsd for more information).

In the advanced XML list standard, alias quality is represented as a Boolean attribute of the alias element. This attribute, "LowQuality" can be flagged as either "true" or "false." If the LowQuality attribute is false then the alias is strong. If the LowQuality attribute is true then the alias is weak.

For more information on the advanced XML standard, please visit OFAC’s SDN data formats page at https://ofac.treasury.gov/specially-designated-nationals-list-data-formats-data-schemas.

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

A person who processes an unauthorized transaction involving a sanctions list entry has violated U.S. law and may be subject to an enforcement action. Generally speaking, however, if (i) the only sanctions reference in the transaction is a weak AKA, (ii) the person involved in the processing had no other reason to know that the transaction involved an entry on one of OFAC's sanctions lists or was otherwise in violation of U.S. law, and (iii) the person maintains a rigorous risk-based compliance program, OFAC will not issue a civil penalty against an individual or entity for processing such a transaction.