By Gil Irizarry
Name matching is vitally important. At Babel Street, we get that. We understand that financial institutions, law enforcement agencies, national security organizations, healthcare systems, and others must link the right records to the right person: to the correct “John Smith” or the appropriate “Mary Jones.” Otherwise, people with no money and terrible credit can obtain large mortgages. Money launderers can operate freely. U.S. Customs and Border Protection may welcome terrorists into the United States, while denying entry to families who want to visit Disney World.
There’s nothing funny about inaccurate name matches.
Except sometimes.
Sometimes, when the goofs are jaw-dropping and the consequences minor, name-matching fails can merit a giggle.
In finance
Didn’t the original Robin Hood know who he was taking money from?
Robinhood Markets is a commission-free stock trading and investment app. Its crypto division enables users to buy and sell Bitcoin, Ethereum, and a variety of other cryptocurrencies. In 2019, it processed about 106,00 transactions daily — without using an automated transaction monitoring system. In late 2022, the New York State Department of Financial Services levied a $30 million fine against Robinhood. The state maintained that the company’s anti-money laundering (AML) program was inadequately staffed, and that Robinhood failed to implement, in a timely way, an AML system adequate to its transaction volume.[1]
We politely asked the terrorists to wait for our SDN list to update
MidFirst Bank, based in Oklahoma, thought it was doing the right thing — contracting with an outside vendor for daily screening of customers against the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) list of Specially Designated Nationals and Blocked Persons (commonly called the “SDN list”). The problem? The bank didn’t realize that its screening vendor only updated its SDN list monthly. Sanctioned persons took advantage of this lag time to evade detection and process transactions.[2]
The Cellblock H address should have been a clue …
OFAC fined MoneyGram more than $34,000 for fuzzy logic failures that led the company to offer cash-transfer services to sanctioned individuals serving time in United States federal prisons.[3]
My middle initial is W. As in, “Why are you doing this to me?”
Whenever an electronic payment is initiated, the Confirmation of Payee Program in the United Kingdom’s banking system double checks account holder names against account numbers. Before the program’s debut in 2020, payors only needed an account number and sort code (comparable to a routing number in the United States) to initiate a payment. The new program helps verify that the payor isn’t sending money to the wrong account. Sounds great. But the specificity of name matching requirements exceeded the parameters of common sense, leaving some customers unable to make payments or receive funds owed.
Think of it this way. You owe Ishmael W. Cowperthwaite £100. You have his sort code and his account number. Still, your payment attempt is rejected. Why? The name of record for this account is Ishmael Waylon Cowperthwaite. In this case, the system would not accept the middle initial — it needed the payee’s full middle name.[4]
In Travel
His mom didn’t name him “Lord Mayor”
Mícheál Mac Donncha, then mayor of Dublin, had been banned from Israel over his support for the boycott, divestment and sanctions movement. The Palestinian-led movement promotes economic sanctions against Israel.
When Mac Donncha flew into Tel Aviv, Israel, on his way to a conference on the disputed status of Jerusalem — claimed by both Israelis and Palestinians as their capital city — he was nonetheless granted entry. Why? Israeli immigration officials were looking for Micheál Mac Donncha. Mac Donncha’s travel documents referred to him as “Ardmhéara Micheál Mac Donncha.” Officials thought “Ardmhéara” was the traveler’s first name. The word means “Lord Mayor.”[5]
It’s the terrible twos, not the terrorist twos
Being incorrectly named to no-fly lists can be devastating, curtailing opportunities for both travel and business. The American Civil Liberties Union publishes an infographic describing the situation’s effects on everyday United States citizens. Similar consequences affect innocent would-be travelers worldwide. It’s not a funny situation. But it’s particularly galling when banned travelers may still be wearing diapers.
In 2018, the parents of three-year-old Canadian Sebastian Khan noticed that every flight required in-person check ins, phone calls from gate agents to authorities unknown, and other procedures. The reason? The name “Sebastian Khan” appeared on a Canadian no-fly list.[6]
The Khans weren’t the only family to experience this. In fact, young children appeared on the list so frequently that in 2016 concerned parents founded No Fly List Kids, a grassroots advocacy program. The Canadian government responded. In 2022, it began rolling out Canadian Travel Numbers, unique identifiers for passengers with names similar to those appearing on that country’s no-fly list.[7]
In consumer services and government
You mean there’s more than one John Smith?
A consumer sued TransUnion credit bureau after being denied an auto loan. TransUnion had flagged the consumer’s name for appearing on the SDN list. The problem? TransUnion failed to use any other identifying information — such as a birth date or social security number — to verify the name match. When the plaintiff disputed TransUnion’s finding, the credit reporting agency allegedly refused to reexamine its determination.[8]
This is not an isolated case. In fact, the United States Consumer Financial Protection Bureau lists identity errors first on its ranking of common credit report mistakes. Identity errors include incorrect listings of a consumer’s name, phone number or address; and accounts belonging to one person being incorrectly appended to the records of a different consumer. In late 2021, the Bureau issued an advisory opinion stating that, in order to comply with the Fair Credit Reporting Act, consumer reporting agencies must match identities using more than a first and last name.[9]
At roughly the same time, the Bureau issued a second advisory opinion stating that consumer reporting agencies — including those that conduct employment and tenancy screenings — violate the law if they use “shoddy” name-matching processes that may lead to applicants being inappropriately denied jobs or housing. In its opinion, the Bureau notes that incorrect name matches disproportionally affect Hispanic, Black, and Asian populations because “there is less surname diversity in those populations compared to the white population.”[10]
Paying a lot for “nothing”
In 2016, Joseph Tartaro ordered a vanity license plate from the State of California. It spelled out NULL. (His wife’s plate read VOID). This resulted in more than $12,000 in unwarranted traffic fines, many for parking violations in cities he’s never visited. Why? Any time a police officer forgot to note license plate information when writing a citation, the system marked it as “null.” And sent the citation to Tartaro.[11]
A better way
Accurate, precise name matching is vital to everything from stopping terrorists to ensuring job applicants are judged fairly.
The Rosette text analytics platform leverages machine learning and artificial intelligence to ease name-matching processes. It enhances names with other pieces of data — ages, addresses, and places of birth among them — for the type of precise name matching that enables you to distinguish one “Joe Jones” from another, and to avoid doing businesses with sanctioned entities and addresses. Fine-tuning capabilities help you determine whether, for example, you need the entire middle name “Waylon” for a match, or if the middle initial W will do.
Don’t get stuck with name-matching technologies that fail to meet either watchlist compliance mandates or your business needs. Read more about Rosette.
End Notes
[1] https://www.cnbc.com/2022/08/02/robinhoods-crypto-division-fined-30-million-by-new-york-regulator.html. “Robinhood’s crypto division fined $30 million by New York financial regulator.” 2022 ↩
[2] https://www.flexi-news.com/post/midfirst-bank-escapes-punishment-in-the-resolution-to-ofac. “MidFirst Bank escapes punishment.” 2022 ↩
[3] https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210429. “Settlement Agreements between the U.S. Department of the Treasury’s Office of Foreign Assets Control and MoneyGram Payment Systems, Inc., and SAP SE.” 2022 ↩
[4] https://www.theguardian.com/money/2020/sep/06/who-am-i-a-bank-security-check-that-leaves-you-guessing-your-own-name. “Who am I? A bank security check that leaves you guessing your own name.” 2020 ↩
[5] https://www.irishpost.com/news/misspelling-irish-lord-mayors-name-leads-mishap-trip-israel-153193. “Misspelling of Irish Lord Mayor’s name leads to ‘mishap’ on trip to Israel.” 2018 ↩
[6] https://theworld.org/stories/2017-11-30/3-year-old-held-canada-s-no-fly-list-his-parents-say-it-s-ridiculous. “A 3-year-old held up by Canada’s no-fly list? His parents say it’s ‘ridiculous.’” 2018. ↩
[7] https://globalnews.ca/news/8588435/canada-no-fly-list-personal-code. “More than 850 Canadians get promised code to avoid no-fly list false flags.” 2022 ↩
[8] https://www.natlawreview.com/article/use-ofac-data-spotlight-consumer-reporting-agency-sued-again-false-positive. “Use of OFAC data in spotlight: Consumer reporting agency sued again for false positive terrorist watch list data in consumer reports.” 2022 ↩
[9] https://www.federalregister.gov/documents/2021/11/10/2021-24471/fair-credit-reporting-name-only-matching-procedures. “Fair Credit Reporting: Name-only matching procedures.” 2021 ↩
[10] https://www.consumerfinance.gov/about-us/newsroom/cfpb-takes-action-to-stop-false-identification-by-background-screeners. “CFPB takes action to stop false identification by background screeners.” 2021 ↩
[11] https://www.wired.com/story/null-license-plate-landed-one-hacker-ticket-hell/.“How a ‘NULL’ license plate landed one hacker in ticket hell.” 2018 ↩
