Fuzzy Matching: The JFSC's Must-Do for Effective Sanctions Screening

The Jersey Financial Services Commission (JFSC) has addressed sanction screening and fuzzy matching primarily in two key documents: its 2023 feedback paper on sanctions thematic examinations and its practical guidance on financial sanctions.

Key Points from JFSC on Fuzzy Matching in Sanction Screening

• Effectiveness of fuzzy matching: J
• FSC testing (via AML Analytics) evaluated whether screening tools generate alerts for both exact and manipulated (e.g., variant spellings) sanctioned/PEP names.
• In the main, supervised persons effectively use ‘fuzzy matching’ functionality to identify potential matches.
• Findings and issues identified:
• One case where screening was below expectations, specifically because it was not utilising ‘fuzzy matching’ functionality.
• Recommendations to review alerts and, if needed, adjust ‘fuzzy matching’ rules, configuration, and threshold settings.
• Emphasis on using up-to-date tools/versions, as outdated ones can miss matches even with fuzzy logic.
• Best practice recommendations (directly from JFSC):
• Understand strengths/limitations of screening methodologies (manual vs. automated).
• Assess risks of ‘exact match’ only screening.
• Periodically recalibrate the ‘fuzzy matching’ rules, configuration, and threshold settings of the screening tool to improve effectiveness and efficiency.
• Tailor/calibrate tools to the Jersey business (not just off-the-shelf/group solutions).
• Conduct regular testing of screening tools.
• Monitor alert volumes (including false positives) to keep them manageable and aligned with risk appetite.

Practical Guidance on Screening (Including Fuzzy Matching)

JFSC's financial sanctions practical guidance states that for automated customer screening to be effective:

• Understand the capabilities and limits of any automated system.
• Ensure matching criteria are relevant and appropriate.
• Use fuzzy matching (e.g., to identify similar/variant spellings of names, name reversal, digit rotation, character manipulation, etc.).
• Prominently flag matches.

Fuzzy matching

• Helps detect potential matches when data is misspelt, incomplete, or varies.

Sources  (Direct JFSC Links)

1. Main Feedback Paper (PDF, June 2023) – Most detailed on fuzzy matching, testing, and best practices: https://www.jerseyfsc.org/media/6728/sanctions-thematic-questionnaire-feedback-paper-3.pdf
2. Examination Findings Page (summary): https://www.jerseyfsc.org/industry/examinations/examination-findings-and-questionnaires/feedback-from-sanctions-thematic-questionnaire-and-screening-systems-examinations/
3. Financial Sanctions Practical Guidance (last revised Sept 2025, covers use of fuzzy matching): https://www.jerseyfsc.org/industry/international-co-operation/sanctions/financial-sanctions-practical-guidance/

These are the primary official JFSC positions. Fuzzy matching is presented as a standard, expected tool in effective sanctions screening systems, with strong emphasis on calibration, testing, and avoiding over-reliance on exact matches.