In order to clarify its policy on weak aliases or AKAs, OFAC has released the following frequently asked questions and answers.
What are weak aliases (AKAs)?
A “weak AKA” is a term for a relatively broad or generic alias that may generate a large volume of false hits. Weak AKAs include nicknames, noms-de-guerre, and unusually common acronyms. 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 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 introduced to the SDN list.
Where can I find weak aliases (AKAs)?
Weak AKAs appear differently depending on which file format of the SDN List is utilized.
In the TXT and PDF versions of the SDN List, 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]
This convention also is followed in the alphabetical listing published in Appendix A to Chapter V of Title 31 of the Code of Federal Regulations.
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 SDN file. In
these formats, weak AKAs are bracketed by quotation marks. Please see the data specification for these files for more information:
http://www.treasury.gov/resource-center/sanctions/SDN-List/Documents/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 XML version of the SDN List, there is a Type element for each
AKA. The Type can either be 'weak' or 'strong' (see the XML SDN
Schema (XSD file) at:
http://www.treasury.gov/resource-center/sanctions/SDN-List/Documents/sdn.xsd
for more information).
Am I required to screen for weak aliases (AKAs)?
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.
Will I be penalized for processing an unauthorized transaction involving a weak alias (AKA)?
A person who processes an unauthorized transaction involving an SDN 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 SDN 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.
*A series of administrative changes have been made to the SDN list in relation to this new FAQ. These changes were published on 01/21/2011.