How do I handle a match result that looks like a false positive?

False positives are an unavoidable reality of sanctions and PEP screening. Common names can generate hits against listed persons who are entirely different individuals. The key is having a documented, consistent process for investigating every alert — and never dismissing a match without recording your reasoning.

Why false positives occur

Most screening systems use fuzzy matching — they flag names that are similar to, not just identical to, entries on the list. This is intentional, as sanctioned persons often use name variations or transliterations. The result is that common names (particularly in South Asian, Arabic, and East Asian naming conventions) frequently generate alerts against unrelated listed persons.

The investigation process for a potential match

Every alert must be investigated using a systematic comparison of identifiers:

• Full name: Compare all name variants in the listing against your client's verified identity documents
• Date of birth: The single most reliable differentiator — a date of birth mismatch is strong evidence of a false positive
• Nationality and country of birth: Listed persons usually have specified nationalities — check against your client's passport details
• Passport or ID numbers: Where listed, compare against your client's verified ID documents
• Known address or location: Where the listing specifies a location, compare against your client's known address and business location

Documenting a false positive determination

If you conclude that the alert is a false positive, your documentation must record:

• The exact alert that was generated (which list, which listed person)
• The identifiers you compared and the outcome of each comparison
• Your conclusion and the basis for it
• The date of the determination and the name of the person who made it

Do not clear an alert with a single-line note. The documentation must be sufficient for a third party (including AUSTRAC) to understand your reasoning independently.

If the match cannot be ruled out

If, after checking all available identifiers, you cannot confidently rule out a match, treat the alert as a potential true positive. You must not provide services to a confirmed sanctions target. Seek legal advice immediately, report to AUSTRAC and DFAT as required, and freeze any assets you hold for the client.