In recent years it has become critical for financial institutions to know and understand where they and their customers are doing business. The size and frequency of fines levied on banks for sanctions breaches continues to rise, especially by the U.S. government, in both civil and criminal legal actions. The vast majority of these fines have been for banks that have permitted transactions involving embargoed countries.
Guidance from enforcement agencies, through details of enforcement actions, indicate that banks are expected to screen and block payments that may include an indirect reference to a sanctioned country (i.e. words such as Khartoum, or Sudanese). A significant challenge for financial institutions is that regulatory and enforcement agencies do not provide lists of cities and other geographic names in the same way that they provide lists of terrorists. Financial institutions are expected to take their own initiative in addressing these risks of indirect country references.
There are 83 languages in the world that have over 10 million speakers. Each of these languages can have a different word for the same place. For example, the major Syrian city of “Aleppo” is called “Halep” in Turkey. If a bank receives a payment originating from “Aleppo” that is processed by a Turkish bank, it’s very unlikely that the payment will quote “Aleppo” in a nice easy conventional English spelling.
The many names of Aleppo include:
Some languages are written in scripts other than Latin, for example Cyrillic, Greek, and Arabic. These scripts are becoming more important for banks who defy legacy system limitations and implement new solutions that treat the world as it really is, a diverse place.
For list augmentation, SQA America Consulting is able offer financial institutions the SQA CTRP List (Cities, Towns, Regions & Ports List), which includes all of the names for every country in the world. A financial institution can license any relevant portion of CTRP’s master list of 4.5 million names to augment its country screening. The CTRP list is updated monthly. Financial institutions can choose how often they want to receive updates.
The SQA CTRP List can also be leveraged to augment a financial institution’s own customer data by allowing SQA America Consulting to assess the completeness and accuracy of its data via a simple batch process. If the country code information in a customer record is missing, it’s very likely that the field can be populated with the correct information from the CTRP List. In most cases, the accuracy of the country information in a customer record can be validated via the CTRP batch process as well. As many financial institutions are aware, the country code field content is becoming much more critical in alert decisioning, especially in regard to PEP alerts.
SQA America Consulting would welcome the opportunity to answer any questions and/or schedule a time to present our list and data augmentation services. Please contact us at your convenience.