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1. Introduction
Purpose:
An exclusionary report name match service is a powerful tool designed to help organizations mitigate risk and ensure compliance with various regulations. This service leverages data from multiple government sources to identify individuals or entities that have been excluded from participating in certain activities due to various reasons such as fraud, misconduct, or other forms of non-compliance1234.
One of the key data sources for this service is the Specially Designated Nationals and Blocked Persons List (SDN) maintained by the Office of Foreign Assets Control (OFAC)5. This list includes individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific5.
Another important source is the Suspended Counterparty Program managed by the Federal Housing Finance Agency (FHFA)2. Under this program, FHFA may issue suspension orders directing regulated entities to cease doing business with an individual or institution, and any affiliate thereof, for a specified period of time where such party has committed fraud or other financial misconduct involving a mortgage transaction6.
The Department of Housing and Urban Development (HUD) also maintains a Limited Denials of Participation list3. This list includes individuals and entities that have been limited, suspended, or otherwise restricted from participating in HUD programs3.
Lastly, the SAM Entity/Exclusions Extracts API provided by the General Services Administration (GSA) allows users to request entity extracts and exclusion data based on the sensitivity level of the user account and through several optional request parameters4.
By cross-referencing these lists, an exclusionary report name match service can provide comprehensive insights into the eligibility of individuals or entities to participate in various activities. This can be invaluable in helping organizations avoid potential risks and ensure compliance with relevant regulations.
2. How to Use this Report:
The exclusionary report name match service should be used as a tool for risk mitigation and compliance assurance. Here’s how you can effectively use this report:
- Due Diligence: Use the report as part of your due diligence process when entering into new business relationships or transactions. This can help you avoid potential legal and reputational risks associated with doing business with excluded or sanctioned individuals or entities.
- Compliance Checks: Regularly check the report to ensure ongoing compliance with various regulations. If an existing business partner or client appears on the report, you may need to take appropriate action based on the nature of the exclusion and the regulations applicable to your industry.
- Risk Assessment: Incorporate the findings of the report into your overall risk assessment process. The presence of an individual or entity on an exclusion list could be a red flag indicating a higher risk profile.
- Reporting: If required by your industry regulations, use the report to fulfill reporting obligations related to sanctions compliance or other regulatory requirements.
- Internal Controls: Use the report to strengthen internal controls by integrating it into your standard operating procedures. For example, you could require a check against the report before approving new vendors or clients.
- Loan origination Parties: Use this service to check all parties involved in a loan application to insure they are not on one of the agencies exclusionary lists.
Remember, while the report is a valuable tool, it should not be the sole basis for decision-making. It’s important to use it in conjunction with other information and tools as part of a comprehensive risk management and compliance strategy. Always consult with a legal or compliance professional if you have questions about how to use the report in your specific context.
3. Understanding the Exclusionary Analysis
Definition and Purpose of Exclusionary Analysis
Exclusionary analysis is a process that involves cross-referencing an individual’s or entity’s information with various exclusion lists to identify potential matches. The primary purpose of this analysis is to help organizations mitigate risk and ensure compliance with various regulations. By identifying individuals or entities that have been excluded from participating in certain activities due to reasons such as fraud, misconduct, or other forms of non-compliance, organizations can make informed decisions and avoid potential legal and reputational risks.
Methodology Used for the Analysis
The methodology for conducting an exclusionary analysis involves several steps. First, the individual’s or entity’s information is collected and verified. This information is then compared with data from multiple government sources, such as the Specially Designated Nationals and Blocked Persons List (SDN) maintained by the Office of Foreign Assets Control (OFAC), the Suspended Counterparty Program managed by the Federal Housing Finance Agency (FHFA), the Limited Denials of Participation list maintained by the Department of Housing and Urban Development (HUD), and the SAM Entity/Exclusions Extracts API provided by the General Services Administration (GSA). Advanced algorithms, such as Jaro-Winkler, Levenshtein, and Soundex, are used to identify potential matches based on the similarity between names.
Reading and Interpreting the Results
The results of the exclusionary analysis are presented in a report format. Each entry in the report represents a potential match and includes details such as the name of the individual or entity, the source of the exclusion data, and a similarity score indicating the degree of match between the input information and the exclusion data.
It’s important to note that a potential match does not necessarily mean that the individual or entity is definitively the same as the one on the exclusion list. Further investigation may be required to confirm the match. Additionally, the similarity score should be interpreted in the context of the specific algorithm used. For example, a higher score generally indicates a closer match, but the exact interpretation can vary depending on the algorithm.
Remember, while the report is a valuable tool, it should not be the sole basis for decision-making. It’s important to use it in conjunction with other information and tools as part of a comprehensive risk management and compliance strategy. Always consult with a legal or compliance professional if you have questions about how to interpret the results.
4. Name Part Comparison Algorithms
Name part comparison algorithms are computational methods used to
measure the similarity between two strings, often used in the context of
comparing names. These algorithms play a crucial role in various
applications such as data cleaning, record linkage, and natural language
processing. They can help identify potential matches between names, even
when there are minor discrepancies due to typos, abbreviations, or phonetic
variations.
Jaro-Winkler Algorithm
Overview
The Jaro-Winkler algorithm is a measure of similarity between two strings. It
is a variant of the Jaro distance metric, but with a modification that gives
more weight to matches at the beginning of the strings. This makes it
particularly useful for comparing shorter strings and strings where the match
at the beginning is more significant.
Pros and Cons
Pros:
● Efficient for large datasets.
● Sensitive to the length of the strings being compared.
● The order of characters matters, which can lead to lower similarity
scores for strings that contain the same characters but in a different
order.
Use Cases
The Jaro-Winkler algorithm is widely used in applications such as data
cleaning, record linkage, and natural language processing where the task is
to identify similar strings in large datasets.
Levenshtein Distance Algorithm
Overview
The Levenshtein distance, also known as the edit distance, measures the
minimum number of single-character edits (insertions, deletions, or
substitutions) required to change one string into the other.
Pros and Cons
Pros:
● Versatile and can be used to measure the difference between any two
strings.
● Provides a quantifiable measure of how dissimilar two strings are.
Cons:
● Computationally expensive for long strings.
● Does not handle transpositions (swapping of two adjacent characters)
well.
Use Cases
The Levenshtein distance has various applications in fields such as
autocorrect algorithms, data cleaning, DNA sequence analysis, and fuzzy
search.
Soundex Algorithm
Overview
identify words that sound similar.
Pros and Cons
Pros:
● Useful for matching names that are commonly misspelled or have
phonetic variations.
● Efficient for large datasets.
Cons:
● Rooted in English pronunciation and may not work as effectively with
names from other languages.
● Discards a lot of data, which can result in more false positives.
Use Cases
Soundex is widely used in various fields such as genealogy, census data
analysis, and voice assistants where the task is to match names that sound
similar.
Remember, while these algorithms are powerful tools, they should be used in
conjunction with other information and tools as part of a comprehensive
strategy. Always consult with a data science professional if you have
questions about how to use these algorithms in your specific context.
5. Custom Models for Name Matching
Introduction to Custom Models
The strategy implemented to narrow down the final possible matches is
referred to as a scoring model. A scoring model can support multiple filtering
rows of model scores, with each filter row containing five model algorithms.
Each customer can define their own desired scoring Models to be used on
their reviews.
Model Name |
Score Range |
Description |
Note |
Soundex |
0 to 4 |
Scores range from decimal value of 0 to 4, a score of 0 indicates no similarity. A score of 4 represents high similarity (possibly identical) |
This is the standard soundex algorithm. |
Jaro Winkler Base |
0 to 1 |
Scores range in decimal value from a 0 to a 1. A score of 0 is no similarity, 1 is exact match |
The is the variation of the algorithm used by OFAC. There is an inherent flaw in the way data is processed and can result in a score that can be twice the appropriate score. The score sequences from left to right. |
Jaro Winkler Enhanced |
0 to 1 |
Scores range in decimal value from a 0 to a 1. A score of 0 is no similarity, 1 is exact match |
This variation removes the flaw in the base scoring algorithm and performs the scoring sequence from left to right. |
Jaro Winkler Optimized |
0 to 1 |
Scores range in decimal value from a 0 to a 1. A score of 0 is no similarity, 1 is exact match |
This variation scores all possible combination of names and results in the highest score. |
Levenshtein Distance |
0 to 1 |
The score ranges in decimal from 0 to 1 with a 1 being a precise match |
This is the standard Levenshtein Distance score. |
6. How Custom Models Enhance Name Matching
Each filter row has a threshold score for each of the models. The algorithms are used to compare name part components for a name from the request against every record in each of the four data repositories. If all of the actual name part comparison scores meet or exceed the corresponding algorithm score from the scoring row (each model score is an AND condition with regards to the other threshold scores in the same scoring model row), that name will be appended to the possible matches return list.
Each row is an OR condition with respect to the other rows and any single row can result in a name being added to the possible match names list. For example, if there are three rows of scoring algorithms in a model and the name matching scores do not meet all five thresholds for row one and three, but they do for row two because of the combination of threshold scores, then the name will be added to the possible matched name list.
This design flexibility allows the strengths (or pros) of each scoring algorithm to be distinctly emphasized, enhancing the effectiveness of the name matching process.
7. Examples of Custom Models in Action
Scoring model 1 Filter Row
Soundex |
JWB |
JWE |
JWO |
LN |
2.000 |
0.500 |
0.650 |
0.650 |
0.750 |
In this single filter model, a name part match resulting score for each algorithm must equal or exceed the filter scores. This strategy doesn’t take full advantage of the strengths and weaknesses of each algorithm as applied to differing name part combinations such as comparing a name with only a first and last name against a name with four or five name parts. This is especially evident with business names and foreign national names.
Scoring model 4 Filter Rows
Soundex |
JWB |
JWE |
JWO |
LN |
3.500 |
0.500 |
0.500 |
0.500 |
0.500 |
2.000 |
0.500 |
0.850 |
0.500 |
0.500 |
2.000 |
0.500 |
0.500 |
0.850 |
0.500 |
2.000 |
0.500 |
0.500 |
0.500 |
0.850 |
In this example, each row is depending on a high match score from each model (except the JWB). Algorithms tend to do very well with a smaller set of name characteristics. The models do not share the same types of strengths which is why there are multiple models to be applied. The threshold scores in this description are meant to be examples only and not a recommendation for scores to be used. It is up to the customer to gain experience with model flexibility and he results and then apply their own needs.