The devil is in HMT’s details…

Her Majesty’s Treasury provides a format guide for its Consolidated sanctions list. It contains, among other things, the following… 

Other Information

Supplementary data in addition to that in the above categories. This could include gender, nicknames, low quality single name aliases, UN reference number, details of family etc
Alias Type
Prime Alias, AKA (also known as) or FKA (formerly known as)
   

From this, should we infer that low quality aliases and nicknames could be treated differently than any aliases denoted in the Alias Type field? If they were meant to be treated the same, why name them so pejoratively?

Mr. Watchlist thinks – although he is neither a lawyer nor a compliance officer – that one could reasonably apply OFAC’s guidance on the matter here. OFAC’s low quality alias guidance states that one need not match on a low quality alias, but can use it to corroborate other matching elements.

Link:

Consolidated List Format Guide

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