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:
- Character length (shorter strings were assumed to be less effective in a screening environment than longer strings);
- The presence of numbers in an alias (digits 0-9);
- The presence of common words that are generally considered to constitute a nickname (example: Ahmed the Tall);
- References in the alias to geographic locations (example: Ahmed the Sudanese);
- 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.