| Previous sanctions data analyst here. At my previous bank I worked for they follow a process like this: 1. Screen by name and date of birth (sometimes only year of birth only) for all lists (EU, US, Australia, etc); with some tolerance
2. Manually match against address, sex, etc Now for some of these lists, depending on the vendor which is used, they may also have information on where the person(s) were last seen (perhaps they're from China and recently visited UK based on public information); not only their country of residence. So this means, if you happen to have a birthday sufficiently close to someone on the list (+-2 yrs) and they happen to be last seen in the country you reside in, then they would have to do the whole manual checking. Now this seems like a lot of work, but when you consider things like reputation risk of getting caught and the possible fines, banks would rather screw over their own customer (or outright refuse to do certain transactions to certain countries) than doing what is best for their customers. For the other attributes which are available like sex, it is sometimes used, but often for manual checking. Data is often too messy to have a viable real-time solution for screening. It is often cheaper to get someone from India to do it for you, rather than re-haul a whole database to have it done "properly". This is the unfortunate reality. |