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The importance of recognising different naming practices

The importance of recognising different naming practices

When it comes to AML/CFT conferences the presentation given by Dr Fiona Swee-Lee Price at the 2021 FIU / ACAMS Conference was unique. At first glance a presentation on how someone’s name is so critical to an investigation seemed like ‘Investigations 101’. In fact, it turned out to be one of the most interesting presentations of the conference.

As an Onomatologist (someone who studies names), Dr Lee demonstrated that most organisations particularly in western societies are doing themselves a dis-service when designing websites, apps, quoting systems, and application processes. By adopting a Western approach (first, middle, and last name), organisations have made it hard for people from non-Westernised countries to complete forms. In many instances their naming practices (how they write / speak their name) are different and don’t fit with a ‘traditional’ form.

Her main point was that we need to take into account the different naming practices of all customers, so we ensure that correct information is linked to the correct person. This is especially critical when reviewing, risk assessing or investigating individuals regarding suspicious activity. 

If reporting entities are not reporting names correctly (according to different cultures/languages), then investigators and AML/CFT compliance people may have a difficult job understanding and pulling everything together when reviewing and matching financial information.

Definitely food for thought.

Key tips:

  • Increase your understanding of different naming practices. This will assist you in conducting customer due diligence to ensure that any suspicious or high-risk links are matched to the right customer. 
  • With New Zealand society being multi-cultural it makes sense to review your customer on-boarding processes. The normal process of first, middle and surname collection may be somewhat outdated moving forward. Having the ability to cater to different naming practices will not only help with risk mitigation but is likely to strengthen customer relationships.   
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