Sanctions Screening
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R E G U L A T O R Y C O M P L I A N C E
Enabling Technologies for Financial Services
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>> Names Filtering & Sanctions Screening
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Names Filtering & Sanctons Screening: PCS™ OFAC Reporter™
OFAC Reporter™ offers a comprehensive solution for the detection of "sanctioned parties" and terrorists on a global basis to meet regulations mandated by the U.S. Treasury Office of Foreign Assets Control, the EU regulations and National and International legislation.
Highlights:
1. Detects possible violations consistently and accurately across your enterprise for global sanctioning bodies, including OFAC, Bureau of Export Administration, Politically Exposed Persons (PEP'S), Canadian OSFI compliance, EU Consolidated List, UN Consolidated List and more.2. Real-time, intra-day interfaces to all at-risk business systems within your application architecture.3. Multiple, customizable algorithms maximize search accuracy significantly reducing expensive due diligence.4. Specialized tools for efficiently managing violations and exclude lists across the enterprise, including configurable rules.5. Persistent audit trails support stringent regulatory reviews.6. Automatic updates with the most current enhanced sanctioned party data.7. High-volume record processing delivers outstanding speed and performance.8. Able to transcend multiple, disparate business systems.
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SDN Database Maintenance and Distributed Inquiries
The Specially Designated Nationals (SDN) database is electronically delivered to the Financial Institution. It contains all original and alternate entries as specified by the U.S. Treasury. It is further enhanced with major political officials, city names, sea/airports, and party identifiers to increase the probability of finding a match. The SDN database can be modified to include other information to identify a violation or to flag non-OFAC transactions. All modifications to the database are preserved after a new U.S. Treasury SDN distribution. Additionally, a detailed record is maintained of any new distributions, additions, and deletions.
It is essential that each employee have the appropriate tools to facilitate their role in complying with OFAC policy. OFAC Reporter™ offers a powerful inquiry function that can be distributed to all employee workstations. Employees have direct access to the original U.S. Treasury SDN list with detailed displays of the SDN record. All related records for AKA's, alternate addresses, and subsidiaries are linked allowing display of the related information. A suspected name can be searched using both alphabetic and phonetic search rules providing the highest probability of an accurate result. To demonstrate due-diligence, all searches are logged for later review.
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Client Interface and Violation Review (On-Line Filtering)
OFAC Reporter™ offers OFAC filtering (On-Line Filtering) to an application through dedicated Client Interfaces. These Client Interfaces are developed to meet the particular needs of each application that it will interact with. Sophisticated phonetics based algorithms are used to scan both parties to a transaction as well as free-formatted text. Abbreviations, synonyms, noise and foreign words are properly considered to assure the highest probability of finding a true match. All searching is performed against the Treasury's Specially Designated Nationals (SDN) database and other databases included such as EU Consolidated, UN Consolidated and other.
Multiple interfaces can be processed from a single server reducing hardware cost and complexity. The database is kept in memory achieving the highest search performance possible. Client Interfaces can be created to meet the needs of any financial application across multiple, disparate computing environments. Many optional Client Interfaces have already been developed including:
IBM MQ Series SWIFT Alliance Access – IBM MQ, MME and AFT using DOS-PCC format SWIFT Alliance Entry - AFT using DOS-PCC format SWIFT Merva Turbo SWIFT Fedline Cibar ABS Darien Banking Systems NFS Microsoft Named Pipes Intranet ST400 AI-MMS Text File Generic Web ServiceIf an existing interface does not meet the needs of an organization, Prime can develop the required functionality.
Violations
Upon determination of a possible violation by a Client Interface, OFAC Reporter™ will act as required by the particular financial application. It may immediately return the match result to the application or hold the possible violation for confirmation by compliance staff. When the match result is immediately returned, it is the financial application's responsibility to properly deal with the possible violation. When the result is held for confirmation, OFAC Reporter™ will display the complete transaction, highlight the suspected party, and display the original U.S. Treasury or other databse record to facilitate review. An operator could then confirm or reject the violation based upon their review. The transaction can also be annotated to provide a permanent record of issues related to the suspect transaction. In all cases, an audit trail of processing and operator actions is preserved.
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CIF Filtering
High performance batch filtering of very large customer databases and transaction files can be performed using OFAC Reporter™. Names can be checked at the rate of 240,000 per second permitting the review of the largest CIF files. Search results can be reported or made subject to review as preferred. Exclude Name processing will allow the FI to block matches on customer names that are similar to sanctioned names.
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Application Programming Interface
The Application Programming Interface (API) provides an easy to use “tool kit” for adding OFAC filtering to your at-risk business systems. Callable routines can be integrated with a company’s proprietary software or may be included directly in third party applications.
OFAC Reporter™ combines sophisticated searching rules, an extensive SDN database, and a powerful misspelling algorithm to maximize the likelihood of finding an OFAC violation. The database is enhanced with major city names, non-listed government officials, party identifiers such as BIC codes and CHIPS UID’s as they become known.
Following are the specific features of the API.
Text FileCallable Routines
The OFAC Reporter™ API provides a set of callable routines that can be integrated into any financial application. These routines are used to load the SDN database, search for possible matches, and retrieve all information pertinent to a possible match.Abbreviations / SynonymsOFAC Reporter™ uses a list of abbreviations and synonyms to improve the likelihood of finding an OFAC violation. Abbreviations and synonyms are expanded in both the SDN list and in all search text before any comparisons are done.Noise WordsAn extensive list of noise words has been compiled and is removed from search text and the SDN list. Comparisons are then performed against normalized data increasing the probability of finding a true match.Common WordsA list of common words (words often used in financial transactions) is used to isolate parties to a transaction and to improve search performance.Foreign WordsForeign words have been added, as appropriate, to noise word, common word, and abbreviation lists.Excluded NamesNames, which should not be confused with actual SDN’s, are used to minimize false positive rates. Different Exclude Name Rules are used for CIF and transaction filtering to meet their unique requirements.Misspelling RulesAll of the search rules use a spelling algorithm to improve the likelihood of finding a misspelled name within the search text. Misspelling rules are algorithmic eliminating the need to maintain a dictionary.Punctuation and DelimitersA series of rules are used to distinguish between punctuation and delimiters. Context sensitive rules are used for characters that can serve both roles.Line BoundariesSearches are not limited by end of line boundaries. A match can be found against text that spans multiple lines.IntegrationExisting proprietary or commercial OFAC databases can be integrated and used by OFAC Reporter™ . This would be appropriate when an investment has already been made in a proprietary database.PerformanceThe SDN and other lists are all memory resident eliminating the overhead and processing time associated with disk based searches. Names may be filtered at a rate of 240,000 per second.
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SDN and DPL Update Service
The SDN Update Service offers customers using Prime's OFAC filtering products a simple method of receiving changes made to the SDN list by the U.S. Treasury and other databases included. Whenever the Treasury por the other publicers makes a change to the SDN list, a file containing all current entries will be delivered to the customer. This file can easily be added to the existing SDN database preserving any changes made by the customer.
The DPL Update Service offers customers using Prime's OFAC filtering products a simple method of receiving changes made to the Denial Order List by the Bureau of Export Administration. Customers subscribing to this service will receive an updated Denial Order List concurrent with the distribution of the SDN List. This list can easily be added to the existing DPL database preserving any changes made by the customer.
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Security and Audit Trails
A separate security system controls all access to the functions in OFAC Reporter™, enabling a security manager with appropriate rights to create operators and assign processing rights.
Rights issued to an operator also specify a “Scope”. Scope allows the security manager to determine precisely which records an operator is allowed to access. Access can be restricted to specific branches, departments within a branch, as well as to records owned by a particular operator.
Attempted program access, both failed and successful, is recorded to the security database. Additionally, all processing performed within OFAC Reporter™ is recorded to an Events log. Events can be reported in multiple ways and are displayed for both the entire system as well as for specific records.
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Third Party SDN Lists
Third party SDN List such as a National Lists, Regional Lists, Special Purpose Lists, Financial Institution's Private Lists can be imported and used for OFAC filtering for all services that OFAC Reporter™ provides. OFAC Reporter™ utility which imports the third party SDN lists/records expects an XML file as input and an XML configuration (settings) file. The xml input file must comply with the schema file (ofac-party-schema.xsd) which describes (a) List of XML elements and attributes, (b) Mandatory elements and sub elements and (c) Default values if not provided.
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