Identifiers and data quality
Secondary identifiers separate targets from namesakes, and ownership rules extend a designation to companies the list never names.
IN ONE LINE
An everyday analogy: two problems haunt any name-based check.
First, many people share names — a name alone is like a smudged fingerprint, and you need more points of comparison: a birthdate, a birthplace, a passport number.
Second, a banned person can stand behind a company whose name appears on no list at all, the way a landlord can own a shop that trades under a different sign.
Sanctions rules answer both problems: list entries carry extra identifying details so the right person is caught and the wrong one released, and ownership rules extend the ban to companies that listed persons own — even though you will not find those companies by reading the list itself.
WHAT IT ACTUALLY IS
Secondary identifiers are the attributes beyond the name: date and place of birth, nationality, gender, addresses, passport and national ID numbers for individuals; registration numbers, incorporation details, and addresses for entities.
They are what turns a name hit into a decision, in either direction.
Ownership and control rules extend obligations past the list itself.
Under OFAC's 50 percent rule, an entity owned 50 percent or more, directly or indirectly, in the aggregate by one or more blocked persons is itself blocked — even if it appears on no list.
The EU applies an ownership test set at 50 percent or more of proprietary rights, aggregated across designated persons, and adds a separate control test covering entities a designated person dominates by other means.
HOW IT WORKS
The operational consequence: screening the list is necessary but not sufficient.
Ownership exposure cannot be caught by name matching, because the risky entity's name is not on the list — it is caught through customer due diligence, beneficial ownership data, and specialised ownership research, and through investigators asking "who stands behind this counterparty" when other red flags appear.
On the identifier side, the constraint is usually the bank's own data: a customer record without a birthdate cannot be distinguished from a listed namesake, so weak reference data converts directly into alert volume and slower payments.
Ownership analysis is also where legal judgment enters — percentages, indirect chains, and control indications rarely come neatly labelled, and institutions take legal advice before concluding an unlisted entity is in scope.
THE WORDS
- Ownership and control
- The principle that sanctions can extend to entities owned or controlled by designated persons, even when those entities are not listed by name.
- Fifty percent rule
- OFAC guidance that an entity owned 50 percent or more, in aggregate, by blocked persons is itself blocked, even if it is not listed.
READ FIRST
CONNECTED TO
SOURCES
- Revised guidance on entities owned by persons whose property and interests in property are blocked (the 50 Percent Rule) — US Department of the Treasury, Office of Foreign Assets Control
- OFAC Frequently Asked Questions — US Department of the Treasury, Office of Foreign Assets Control
- EU Best Practices for the effective implementation of restrictive measures — Council of the European Union
- Payments Signal editorial teaching models — Payments Signal
Derived from Identifiers and data quality. Every claim on this card is sourced on that page.