[harperlee]

That’s because the combined business of all Muhammads and their employers is way more than 210$/month AND it would be illegal, and Bad PR™, to ban them from your business based just on their culture/name. Otherwise they would have been “derisked” out of service.

[A4ET8a8uTh0]

You have a point ( and Mnuchin to his credit ,based on reports, does care about regulatory burden and its impact ). So you are right, one is not like the other. To address your point directly, if OFAC tomorrow added MOHAMMAD JIHAD with no other information ( no DOB, no address, and so on ), you would be surprised how quickly the banks would respond.

Now note that that we are discussing a name, a commmon, but somewhat reliable, if mutable, driver of our identity. Now compare it to IP address and tell me, which one is a better predictor of who you are.

Unless, we are assuming IP is a proxy for location, which is another story.

[harperlee]

Banks typically would react overnight to OFAC list updates, through a sanctions list service.

If no DOB or similar is also provided, though, scoring should not be too high - and if a match with Mohammad is enough to trigger an alert, the overnight alert delta would be either manually processed by Compliance, or bulk closed as false positives, depending on how much time you need to unblock the clients and similar risk considerations.

[A4ET8a8uTh0]

I am not sure if you realize it, but you are proving my point. Banks found a way to address the issue without adversely affecting the customers. Github appears to have only recently started to do the same, but they opted for a blanket approach as opposed to a more targeted one.

[harperlee]

Sure, I’m just not trying to disprove you, I argued similarly in other threads.