An overnight list update produces a screening alert

Luis Herrera Sánchez is a personal tax client of the firm — a salaried marine engineer, Spanish, living in Malta since 2019. An overnight refresh of the screening provider’s data has produced an alert on his name, matched at 91% against an entry on the EU consolidated list. It is on the MLRO’s desk this morning.

• Client: Luis Herrera Sánchez, a Spanish national resident in Malta since 2019. A client of the firm for three years.
• Services: preparation and filing of his personal Maltese income tax return. No companies, trusts or other structures.
• Identity on file: a certified copy of his Spanish passport — full name Luis Herrera Sánchez, born 14 March 1979 in Valencia, Spain
• Screening record: the only identifier ever submitted to the screening tool is the name “Luis Herrera”. The date and place of birth were never carried across from the file.
• The alert: a 91% fuzzy match against Luis Alberto Herrera Ramírez, born 1961 in Barquisimeto, Venezuela, designated in 2018 under the EU’s Venezuela regime. The list entry carries no photograph and no passport number.
• His affairs: salaried at a Maltese shipyard on around €48,000 a year, with a Maltese current account and a Spanish one kept from before the move
• Screening history: screened at onboarding and at every list refresh since. This is the first alert on him.
• Other results: no PEP and no adverse media results at any point
• Alert volumes: the provider’s match threshold was lowered from 95% to 85% last month. The firm’s queue has gone from around four alerts a month to around sixty, and roughly a third are unworked.
• Rating at onboarding: low