Compliance officers in industries that take shortcuts by solely using the OFAC list to sort out terrorists amongst potential clients, risk being sued by the very individuals that they turn down when false positives are used to deny credit, decline business, or terminate relationships. Statements recently made by lawyers' groups have indicated that they are will conduct litigation against companies who have damaged their clients by such actions. If there was ever a reason for compliance officers to go to management and seek to minimise risk by the acquisition of a KYC database, this is it. Imagine the reputation damage your company would incur if named in a newspaper article as the bad actor in declining an account relationship or a sale, where a consumer was clearly not the terrorist named in the OFAC list, and he was denied a mortgage due to an Arabic middle name that resembled some terrorist's alias.

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