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Reviewing a potential match

What is a potential match?

When AML Simple flags a potential match, it means the client’s name or details are similar to an entry on the DFAT Consolidated List. Most potential matches are false positives — the same or similar name belonging to a different person.

You must review every potential match before proceeding with a transaction. Do not proceed while a match is unresolved.

Step-by-step: reviewing a potential match

  1. Open the client record in AML Simple and go to the Screening tab
  2. Select Review match to open the match details
  3. Compare the information side by side:
    • Full name (including middle names and alternative spellings)
    • Date of birth
    • Nationality or country of origin
    • Any other identifying details shown
  4. If the details clearly relate to a different person, select Dismiss as false positive and enter your reason in the notes field. Be specific — for example: “Date of birth does not match. Client is Australian-born; listed person is a foreign national.”
  5. If you cannot confidently dismiss the match, do not proceed. Escalate to your Compliance Officer.

When you must escalate

Escalate to your Compliance Officer when:

  • The name, date of birth, and nationality all appear consistent with the sanctioned person
  • You cannot obtain enough information to rule out a match
  • The client is unable or unwilling to provide clarifying information

Your Compliance Officer should seek legal advice before taking further action. Do not tell the client that you have run a sanctions check or that a match has been flagged — this could constitute tipping off, which is a criminal offence under the AML/CTF Act.

If the match is confirmed

If you confirm a client is a sanctioned person:

  • Do not proceed with the transaction
  • Do not return funds or assets in a way that would breach the sanction
  • Contact your legal advisor for guidance on your specific obligations
  • Your Compliance Officer should consider whether a Suspicious Matter Report is required

Recording your decision

Every review decision is logged in AML Simple with your name, date, and the reason recorded. This forms part of your audit trail and must be retained for 7 years.