A possible match needs a decision
A screening match occurs when a search identifies a possible connection between customer information and another record. The record might concern a different person.
A false positive is an alert that does not concern the person or entity being examined. A similar name alone cannot settle the identity question.
Sources: DFAT: Name Type; Date of Birth; Place of Birth; Additional Information; AUSTRAC: How to establish if an individual is a PEP.
Compare relevant details
DFAT’s Consolidated List can contain aliases, dates and places of birth, addresses and other identity information. Some details are known or suspected.
A suggested review compares these details with reliable customer evidence. It records agreements, differences and missing information. One conflicting field does not always settle the result.
The list entry and the customer evidence both need examination. A similarity score is not a legal determination.
Source: DFAT: Name Type; Alias Strength; Date of Birth; Place of Birth; Address; Additional Information.
- Possible connection
A search identifies a possible connection with another record.
- Evidence
Compare available identifiers. Record agreements, differences and missing information.
- Decision
Record the reasons for the result or the remaining uncertainty.
Resolve the identity question
Suggested review process. A similar name or one conflicting field does not always settle the result.
Follow the process from top to bottom.
Identify the type of alert
A politically exposed person (PEP) result, a sanctions result and adverse media answer different questions. They can require different actions.
The PEP article gives the relevant status and CDD duties. The sanctions article gives the separate sanctions boundary. Additional CDD does not permit a prohibited transaction.
If the available evidence cannot resolve the match, the business needs further examination under its policies before treating the alert as false.
Sources: AUSTRAC: How to establish if an individual is a PEP; DFAT: Activities associated with designated persons and entities.
Two people with the same name
A fictional search finds a listed person with the same name as a customer. The file has reliable evidence of a different birth date.
The reviewer also compares the other available identifiers. The record then states why the combined evidence supports different identities, or why uncertainty remains.
The result concerns this alert and this evidence. It is not a permanent exemption from future screening or other customer checks.
Source: DFAT: Date of Birth; Place of Birth; Additional Information.