Moon ScanWhat to do when a name screening returns a match
A step-by-step disposition workflow for screening hits — telling false positives from true matches, when enhanced due diligence applies, and what to write down.
Most hits are not your customer
Screening compares names, and names collide. Common surnames, transliteration variants (one Chinese name can have several romanisations), abbreviated company names, and aliases all produce candidate matches that have nothing to do with your customer. A hit is the start of a check, not a conclusion — the goal of the disposition workflow is to resolve it defensibly, in either direction.
Equally, do not wave hits through. Clearing a match without recording why is as bad in an inspection as missing it entirely, and a genuinely designated party slipping through carries criminal exposure. Slow down for the small number of hits that matter.
Step 1 — Is it the same person or entity?
Compare every identifier you have against the listing: date of birth, nationality or country, registration or passport numbers, addresses, and known roles. Official list entries usually carry several of these; corporate registries and the customer’s own CDD documents supply your side.
Weight the name match itself sensibly. An exact match on a distinctive full name is a strong signal; a fuzzy 70% similarity on a common name is weak. Moon Scan only counts matches of at least 85% name similarity toward the verdict, and shows lower-scored candidates separately so you can see what was considered and set aside.
Step 2 — What kind of list is it?
Not every list means stop. A strong match on a prohibitive list — sanctions, terrorism, crime, wanted, or debarment — means do not proceed until the match is resolved, and escalate to your compliance officer immediately.
A strong match on a politically exposed person (PEP) list is different: being a PEP is not an offence and is not a reason to refuse business. It triggers enhanced due diligence — senior management approval, establishing source of wealth and source of funds, and closer ongoing review. Our PEP screening guide covers those steps in detail.
Step 3 — Escalate, decide, and where required report
For a confirmed true match on a sanctions or terrorist list, Hong Kong law prohibits dealing with the designated party’s property and requires disclosure: suspicious transaction reports go to the Joint Financial Intelligence Unit (JFIU). Take legal advice as needed, and take care not to tip off the customer — telling them a report has been made is itself an offence.
For confirmed PEPs, record the enhanced due diligence performed and the senior-management approval to continue. For cleared false positives, record what identifiers you compared and why the match failed. The decision is only as good as its written reasoning.
Step 4 — Keep the evidence
Keep the screening report itself (names queried, date, dataset version, hits, verdict) together with the disposition: who reviewed it, what they checked, and the outcome. Hong Kong AML record-keeping runs at least five years from the end of the business relationship, and screening records follow the same discipline.
Every Moon Scan scan can produce a one-page, date-stamped PDF with the dataset version on it — file it with the disposition note and the client’s CDD records, and re-screen when lists update so the file shows a living trail, not a single onboarding snapshot. See our TCSP requirements guide for when re-screening is required.