Data Source Rules

OFAC

In Sentinel Phase II, the rules for returning high-level results from the OFAC Sanctions Program and Country Summaries:

Medium: Applicant country matches country in list
Medium: Applicant citizenship matches country in list
Low: everything else

In Sentinel Phase II with IDS name matching, the rules for returning high-level results from the OFAC list are:

High: match of applicant name against individual names in OFAC.
High: match of applicant name with alternate names associated with individuals in OFAC.
High: match of applicant addresses with home address.
Medium: Company name matches either primary or alternate name for commercial entities.
Low: everything else.

BXA Denied Persons

In Sentinel Phase II using IDS, the rules for returning high-level results from the BXA Denied Persons list are:

High: exact match of names against applicant name or company name today in expiration date.
High: exact match of addresses with home or employment address and today in expiration date.
Medium: exact match of either name or address but today not in expiration date.
Low: everything else.

World Bank Ineligible

In MLDS Sentinel II, the rules for returning high-level results from the World Bank Ineligible list are:

High: match applicant company name with part of company_name and match of city or state.
Medium: match applicant company name with part of company_name.
Low: everything else.

Politically Exposed Persons

In Sentinel Phase II, the rules for returning high-level results from the politically exposed Persons (PEP) list are:

High: First name with part of first name, last name with part of last name and country match.
Medium: First name with part of first name, last name with part of last name and no country match.
Low: everything else.

FBI Most Wanted

In Sentinel Phase II, the rules for returning high-level results from the FBI Most Wanted Terrorist list are:

High: Applicant first name with part of name, last name with part of name.
Low: everything else.

In Sentinel Phase II, the rules for returning high-level results from the FBI Most Wanted Fugitives list are:

High: Applicant first name with part of name, last name with part of name.
Low: everything else

Non-Cooperative Countries and Territories

In Sentinel Phase II, the rules for returning high-level results from the NCCT list are:

High: Applicant County or applicant citizenship matches county on list.
Medium: Company Country matches country on list.
Low: everything else.

EU Terrorist List

The Council of the European Union on December 27th of 2001 issues position 931 that lists terrorists and terrorist groups subject to full judicial cooperation and possible freezing of funds for any person or group listed in the Annex. The list will be updated not less than every 6 months. All versions of the list are available at: http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=32001E0931&model=guicheti First and Last name, birth data and alternate birth date, birth city and country, national id card number, passport number and country, and citizenship.

There are currently 45 records in the list. 97% have a DOB. 46% have a national id or passport number. Only 13% have citizenship.

The following data is available in the EU List:

High: Name, DOB, or alt DOB, and Citizenship all match
High: Name, DOB, or alt DOB, and Citizenship all match
High: Name, and DOB and Citizenship is null or matches
High: National ID number or passport number match
Medium: Name match DOB is null or no applicant DOB or is within 8 years + or –
Medium: Company name matches CSFP Name WHOLENAME. (Only where ENTITY_TYPE = E)
Low: everything else.

Bank of England Consolidated Sanctions List

The Bank of England Consolidated List contains targets that have been listed by UN, EU and UK under legislation relating to Al-Qa’ida & Taliban, Burma/Myanmar, Federal Republic of Yugoslavia & Serbia, Iraq, Liberia, Terrorism and Zimbabwe.

High: Applicant name matches “Individual” record
High: Applicant address matches “Individual” record
High: Company name matches “Entity” record
High: Company address matches “Entity” record
High: National ID or Passport Number matches
Low: everything else.

UN 1267 Committee List

The Security Council Committee established pursuant to paragraph 6 of resolution 1267 (1999) (hereafter referred to as the 1267 Committee) oversees the implementation by States of the sanctions imposed by the Security Council on individuals and entities belonging or related to the Taliban, Usama Bin Laden and the Al-Qaida organization and maintains a list of individuals and entities for this purpose. In resolutions 1267 (1999), 1333 (2000), 1390 (2002) and 1455 (2003) the Security Council obliged all States to freeze the assets, prevent the entry into or the transit through their territories, and prevent the direct or indirect supply, sale and transfer of arms and military equipment with regard to the individuals/entities included on the list.

http://www.un.org/Docs/sc/committees/1267/1267ListEng.htm

High: Name or High Quality Alias Matches
High: Address Matches
High: National ID or Passport Number matches
Low: everything else

Executive Order 13224

President Bush signed Executive Order 13224 on September 23, 2001. Executive Order 13224 gives the U.S. government a powerful tool to impede terrorist funding and is part of our national commitment to lead the international effort to bring a halt to the evil of terrorist activity. In issuing Executive Order 13224, President Bush declared a national emergency to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States posed by grave acts of terrorism and threats of terrorism committed by foreign terrorists. In general terms, the Order provides a means by which to disrupt the financial support network for terrorists and terrorist organizations by authorizing the U.S. government to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism.

http://www.state.gov/s/ct/rls/fs/2002/16181.htm

High: Name or High Quality Alias Matches
High: Address Matches
High: National ID or Passport Number matches
Low: everything else

Politically Exposed Persons and High Risk Individuals (Private Data Source)

This list provides intelligence on heightened risk individuals and entities. Data focuses on Politically Exposed Persons and their associates but also includes terrorists, drug dealers, financial crime, and other undesirable categories. (All name matches include name and alternate spellings and alias)

Person Searches

Generally speaking matches are “High Risk” if all filter criteria match: Name, Citizenship, Location and Date of birth. If only one of the criteria does not match then matches are Medium Risk. See details below:

High: Individual Name match, citizenship match, location match, and DOB matches
Medium: Individual Name match, citizenship match, location match and DOB or “Age as Of” does not match but is within an acceptable range (within 1.1 years + or -)
Medium: Individual Name match, citizenship does not match, location match and DOB or “Age as Of” matches or is within an acceptable range (within 1.1 years + or -)
Low: Name does not match (OR)
Low: Citizenship and Location* do not match (OR)
Low: Location does not match (OR)
Low: DOB does not match and is outside of acceptable range (within 1.1 years + or -)

Entity (Company) Searches

High: Company name matches name and location of company matches W-C citizenship of company
Medium: Company name matches name and no location data is available
Medium: Company name matches and citizenship does not match but company location does match
Low: Company name does not match (OR)
Low: Citizenship and Location* do not match (OR)
Low: Location does not match (OR)

Notes

Except for items marked with an * matches for DOB, Citizenship and Location include actual matches or cases where the data is not available.
All location matches are based only on country