For compliance databases, a ‘no hit’ isn’t a green light
The recent Cobham Holdings Inc. OFAC settlement highlights a limitation in due diligence software: Cobham’s screening partner ran a name through a database and received no hits.
The name was later found to be a variation of a hit from the OFAC sanctions list, but wasn’t picked up due to the limitations of the search parameters.
While companies who find themselves in this situation look to and hold their screening partner responsible, database and continuous monitoring services should be considered a minimum tool available for a compliance program’s due diligence.… Continue Reading