Identifying Sanctions Evasion Through Name Alteration Checklist for TFS, CFT & CPF Compliance

With Regulated Entities upping their ante with best-in-class Sanctions Screening Software and Sanctions Screening APIs, criminals also find ways to escape this cat and mouse chase!

One method to escape deeper scrutiny is name alteration, name variation, or misuse of aliases to evade identification or matching names contained in sanctions lists. Name alteration or name manipulation is a Sanctions Evasion technique, that criminals use to disconnect their names with their true identities which tie them to prohibited activities that led to inclusion of their names in sanctions or designated persons lists. Name alteration preys on limited data linking capabilities of screening software and APIs. Identification of name manipulation is a must during CDD to ensure that criminals do not pass sanctions screening.

Here’s a “one-click-away” downloadable, “Identifying Sanctions Evasion Through Name Alteration Checklist for TFS, CFT & CPF Compliance” + RACI Matrix.

Whether you are a part of the customer onboarding team, an AML Compliance Officer, a KYC Analyst, a Transaction Monitoring Analyst, or a Senior Board Member, or simply an AML enthusiast, this checklist is specifically designed to simplify your and your teams’ responsibilities such as:

• Assessing the effectiveness of control measures surrounding documents, customers, transactions, and counterparties to identify or detect any red flags indicating sanctions evasion through name alteration
• Identifying whether the regulatory reporting and AML training components are designed well enough to mitigate sanction evasion risks
• Identifying process efficiency for red-flag detection around misuse of aliases to evade scrutiny, which might be indicators of underlying ML, FT, or PF activities
• Designing workflow, role clarity, task allocation, and task escalation for managing cases with name variation monitoring
• Ensuring timely filing of CNMR, PNMR, SAR, or STRs with UAE FIU through goAML portal when alias related sanction evasion red flags are detected.

Download this Identifying Sanctions Evasion Through Name Alteration Checklist for TFS, CFT & CPF Compliance, whether you are in Dubai, ADGM, or DMCC to align your regulated with realistic name alteration detection red-flags and assess your business’s readiness to mitigate sanctions evasion risk to combat TF and PF risks.