Yesterday the Office of Foreign Assets Control (“OFAC”) announced that it had fined Citigroup $217,841 in connection with its processing certain transactions involving Iran and one involving a Syrian entity on the Specially Designated Nationals and Blocked Persons List (the “SDN List”).

The SDN List issue is particularly interesting because the SDN List had what may be an incorrect name for the SDN involved and Citigroup, which had what appears to be the correct name, failed to block the transaction. At issue is Syria’s Higher Institute for Applied Science and Technology (“HIAST”) which appears on the SDN List as the Higher Institute of Applied Science and Technology. When Citibank ran a computer program to screen the name”Higher Institute for Applied Science and Technology” it didn’t pick up the “Higher Institute of Applied Science and Technology” because it was not an exact match.

Notwithstanding OFAC arguably getting HIAST’s name wrong,* it is fairly clear that screening procedures need to employ at least some fuzzy logic and not insist on exact word-for-word, letter-for-letter matches, particularly where many of the names on the SDN List have been transliterated or translated into English. The OFAC announcement indicated that Citigroup had “implemented a programmatic fix” of some kind, one which would apparently allow “of” to match “for” and vice versa.

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*HIAST’s Facebook page uses “Higher Institute for Applied Science and Technology” as does Wikipedia and most other sources. Oddly, HIAST’s webpage uses “Higher Institute of Applied Sciences and Technology.” Only OFAC appears to be using “Higher Institute of Applied Science and Technology.” Given OFAC’s almost comical reliance on AKAs for many other listings, there is no reason for it to fail to add all the known variants in HIAST’s listing. That way even stupid systems would pick up the match

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