Sanctions Evasion Reference

Fuzzy matching

Name-matching that tolerates spelling, transliteration and word-order variation, scoring similarity rather than requiring an exact match.

reviewed

2026-08-20

Sanctions lists are multilingual and the same Arabic, Cyrillic or Chinese name can be romanised several defensible ways. Exact matching would miss almost everything, so screening systems score similarity and alert above a threshold.

The consequences run both ways. A threshold set for a manageable alert volume will miss deliberate minor variants, and evasion that relies on that is well documented. Conversely, most alerts are false positives, and the labour of clearing them is a real constraint on how tightly a system can be tuned.

Where this term is used

  • How is correspondent banking used to evade sanctions? — Using a chain of banks that each know only their own customer, so that a payment for a restricted party reaches a currency it could not access directly, without any bank in the chain seeing the whole transaction.
  • What is a front company? — A front company is a business that trades normally but exists largely to hide another party's involvement in its transactions. The real activity is the cover; the concealed party is the point.
  • What are third-country bank accounts and how are they used? — Holding accounts in a jurisdiction unconnected to the restricted party, the goods or the contract, so that payments reach and leave the restricted economy without ever appearing to touch it.

Related terms

  • Screening — Automated comparison of names, identifiers and other transaction data against sanctions lists and internal watchlists, at onboarding and on each payment.
  • Specially Designated Nationals and Blocked Persons List — The principal United States sanctions list. Property of anyone on it is blocked and US persons are generally prohibited from dealing with them.
  • Designation — The formal act of adding a person, entity, vessel or aircraft to a sanctions list, which triggers the restrictions attached to that programme.

Sources

  1. Frequently Asked Questions. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Consolidated Screening List. U.S. International Trade Administration, 2026.

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