SAN005 · Sanctions

Name Screening Evasion

Name Screening Evasion is the defeat of list-based screening through the *form of the name*: aliases, transliterations, suffix variants, deliberate misspellings and word re-orderings that let a listed party transact under a name an exact-match filter never flags. The party is on the list; the name on the paperwork is engineered not to match it.

Unlike the other analytics in this suite — which score an entity's *network and behaviour* through a weighted, multi-component exposure model — SAN005 is a matching capability. The question it answers is narrow and hard: does this presented name refer to a listed party, even when it is not spelled the way the list spells it? The finding is the match itself, its strength, and the severity of the list it lands on.

Risk indicators

Match

• A STRONG / FUZZY (non-exact) match above the 0.85 threshold — a variant that still resolves to a listed party
• A match landing on an alias rather than the primary listed name
• Multiple near-duplicate entities matching the same listed party

List

• Sanctions-list hit (severity 90)
• PEP hit (severity 70)
• Adverse-media hit (severity 55)

Investigation actions

1. Normalise the presented entity names and the watchlist (primary names + aliases).
2. For each entity, score similarity against every watchlist entry and its aliases.
3. Keep each entity's single best entry above the 0.85 threshold.
4. Band the match (EXACT / STRONG / FUZZY) and set severity from the list type.
5. Emit one strongest screening hit per entity; escalate sanctions hits.

Detection logic

1. Normalise the presented entity names and the watchlist (primary names + aliases). 2. For each entity, score similarity against every watchlist entry and its aliases. 3. Keep each entity's single best entry above the 0.85 threshold. 4. Band the match (EXACT / STRONG / FUZZY) and set severity from the list type. 5. Emit one strongest screening hit per entity; escalate sanctions hits.

Related typologies

Curated from fc-05-sanctions-exposure-analytics-toolkit/typologies/SAN005_Name_Screening_Evasion.md