How Does Passthrough Match Investors Against Sanctions Lists?

Passthrough uses fuzzy name matching to compare investors against several sanctions lists provided by the Office of Foreign Assets Control (OFAC).

Scoring

We give each match a percentage score. The more similar an investor's name is to a name on the sanctions lists, the higher the score. It is up to your organization to decide what kind of diligence to do for different match scores.

Our scoring algorithm incorporates the similarity of the names as text, as well as their similarity when spoken out loud. To do this, we use the Jaro-Winkler algorithm to compare text similarity, and the Soundex algorithm to compare phonetic similarity. This is the same technique used by the Treasury Department's tool offered to the public, and consequently Passthrough generates similar scores.

Lists

Our sanctions lists are updated hourly, and name matches happen in real-time upon viewing an investor's profile.

The following OFAC provided lists are searched:

  • Specially Designated Nationals And Blocked Persons (SDN)

  • Foreign Sanctions Evaders (FSE)

  • Sectoral Sanctions Identifications (SSI)

  • Palestinian Legislative Council (NS-PLC)

  • The List of Foreign Financial Institutions Subject to Part 561 (the Part 561 List)

  • Non-SDN Iranian Sanctions Act (NS-ISA)

  • List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA)

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