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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.
Client Interface and Violation Review
OFAC Reporter offers OFAC 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. 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
- Text File
- Intranet
- ST400
- AI-MMS
If an existing interface does not meet the needs
of an organization, Prime can develop the required
functionality.
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 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.
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.
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.
Following are the
specific features of the API. 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.
Callable 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 / Synonyms
OFAC 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 Words
An 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 Words
A list of common words (words often
used in financial transactions) is
used to isolate parties to a transaction
and to improve
search
performance.
Foreign Words
Foreign words have been added, as
appropriate, to noise word, common
word, and abbreviation
lists.
Excluded Names
Names, 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 Rules
All 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 Delimiters
A series of rules are used to distinguish
between punctuation and delimiters.
Context sensitive rules are used for
characters that can serve both
roles.
Line Boundaries
Searches are not limited by end of
line boundaries. A match can be found
against text
that spans multiple lines.
Integration
Existing 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.
Performance
The 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.
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. Whenever the Treasury 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.
[integrate this content with Compliance Databank?]
Security and Audit Trails
A separate security system controls
all access to the functions in BSA 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 BSA 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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