
How the US Treasury imposes sanctions on me and every other "Stephen Law" - slyall
http://stephenlaw.blogspot.com/2014/02/how-us-treasury-imposes-sanctions-on-me.html
======
codegeek
Stuff like this makes one wonder that even though unfortunate, it is time to
consider naming your babies with names that are extremely unlikely to be
common. heck, may be even add a salt to it while we are at it. Ok the salt
part is a joke but seriously, one has to feel for those who share their names
with people on these "special" lists by Governments.

May be a start-up idea for prospective parents to run the names and ensure
that before they name their babies, those are not on some list. But then what
if someone gets on the list later on ? So it seems like a very unique name is
really the option.

Also, do these special lists really flag people just by their names ? really ?
I mean how many John Smiths can there be in this world and god forbid if one
of them decides to do something "special". What about other attributes ? Is it
really hard to have the unique key as (first name,last name, gender, age,
place of birth, citizenship, blah blah) instead of just (first name, last
name) and boom, you are flagged.

EDIT: Based on some comments, it might be a good idea to have a legal name
that is very unique and a social name/nickname that is the usual John Smithy
type. This way, when you deal with legal/customs whatever, use the crazily
unique legal name while on the internet, use a nickname.

Also, while we are discussing names, I seriously suggest you to register
domain names (and gmail/fb whatever) for yourself and kids if not already.
Again unfortunate, but reality of this era. I have already booked domains
names for my 1 year old and another one who is coming soon.

~~~
iheartmemcache
There's an interesting downside to naming your child something very unique-
you become significantly more Google-able than "Tom Jones". Potential
employers, landlords, spouses, and other people will have a very easy time
seeing all of your failures and folly.

~~~
Alex_MJ
THIS. I have a unique last name - there is absolutely no ambiguity whenever
anything shows up.

Whenever a website (or anything offline that might put rankings or whatever
online) wants me to use my real name, I usually default to "Alex", "Alex M/MJ"
or "Alex (gibberish)" depending on their guidelines. What they view as a
policy that "encourages openness", I view as something that will guide first
impressions when people google me unto eternity.

Even if it's not controversial, it's the first thing a potential client or
employer sees when they type things into google, and I don't want to be
reckless with that. I don't want to have to view every minor action that I
make on a website as something that's potentially going to be on the front
page of google's results for my name.

When I was in HS, my friends had a poker league, and we all had nicknames and
personas - someone put up a page with hilarious (but decidedly unprofessional)
caricatures and quotes and it was the first thing that showed up under my
name. I noticed it and asked my friend to change it, which he though was
hilarious but understood and did.

Same for Meetup. A long time ago I went to some meetups that could potentially
be alienating to some folks (agnostics and whatever, way back in the day when
I felt it was worth arguing about) and BOOM, google front page for my name. If
I had a client who was somewhat religious, I don't care at all but I don't
want that to show up and all of a sudden I'm accidentally alienating people.
For showing up to something.

Whenever I run a 5k or do anything remotely prestigious I always use my full
name so that the front page of google just gets filled with that kind of thing
in case anything else that's potentially a liability pops up and I don't
notice it. It's annoying.

~~~
SomeCallMeTim
I am absolutely delighted that my name is sufficiently unique (and my online
presence sufficiently diverse) that the entire first page of Google results
that shows up is _me_.

>I don't want to have to view every minor action that I make on a website as
something that's potentially going to be on the front page of google's results
for my name.

It's true that I try to make every post to the Internet be something that I
wouldn't worry about showing up in such a search.

But as a result, when people find me, they _do_ have a lot of real data about
me -- and I get job offers and consulting offers _all the time_.

I do not think it's a bad thing to be able to be Googled; what's a bad thing
is to let yourself be a jerk online -- and it's important to Google yourself
from time to time to see if something like your friend's page is showing up.

The Meetup point is a good one, though. It would be nice to be able to
(optionally) conceal your presence in a Meetup. Be it related to atheism or
religion or sexual orientation or recovering alcoholism or even stamp
collecting or trainspotting, there are a lot of groups that one might want to
join that they wouldn't necessarily want to shout about to everyone. And
that's _not_ the fault of having a unique name -- anyone in any Meetup group
that I'm in will certainly be able to "out" me as a member of any other Meetup
group that I'm a member of, even if I'm named John Smith. And it's entirely
likely that I'll share professional Meetup groups with potential employers.

~~~
columbo
> I do not think it's a bad thing to be able to be Googled; what's a bad thing
> is to let yourself be a jerk online

Ehhh, it's not always that.

For awhile I was big into writing speculative/science fiction on a popular
writing site. Years later after reading some of my submissions I have to say
I'm extremely happy that they were done under a pseudonym :)

They were absolutely terrible.

~~~
MartinCron
My favorite local video store (quaint, I know) organizes films by director and
it's always encouraging to walk through there and see that even great
directors sometimes make terrible movies.

------
tdees40
We were flying with my son (then six months old) recently, and he has a
reasonably uncommon name. He was flagged by the TSA as being on the no-fly
list, which caused us to have to submit to onerous additional security
procedures and miss our flight. So, ya know, way to go, TSA.

~~~
mcv
Your 6 month old kid is already a terrorist? Way to go, parent.

~~~
tdees40
I knew I shouldn't have joined that Hezbollah playgroup!

------
coldcode
Having had to learn this in our "ethics training" requirements at work (what a
joke), I was astonished that they actually intend it to be illegal to have any
commerce whatsoever with anyone on with a name on this list. I also realized
that no US company actually filters their sales and order forms against this
data (to my knowledge) and thus everyone is essentially guilt of trafficking
illegally with anyone who has a name on this list. Order a trinket from Amazon
and use a name on the list? Amazon is breaking Federal law. Rent a hotel room
to a name matching one of this list, your OTA is violating a Federal Law.
Other than customs and maybe banking I doubt anyone is even aware of this much
less actually spends any time filtering their customers this way. Despite the
addresses being on the list, like the no-fly lists, the name is the only
requirement to match.

I've always wondered if the President matched a name on the list, would they
hassle him/her as well?

~~~
wolf550e
Possibly yes:
[http://www.nytimes.com/2004/08/20/national/20flight.html](http://www.nytimes.com/2004/08/20/national/20flight.html)

------
DennisP
It keeps astonishing me that the U.S. government treats firstname/lastname as
a unique key.

I don't see a workaround for shipping, but for wire transfers there's bitcoin,
if there's an exchange somewhere that won't have to deal with this when
converting money back to your national currency. (Perhaps someday, bitcoins
will be spendable enough so that step won't be necessary.)

~~~
henrikschroder
The saddest part of the obsession with names in the US is that the systems in
place are woefully inadequate when it comes to handling names that fall
outside the standard US pattern of Firstname Initial Lastname, all in ASCII.

My name contains the character ö, so every time I'm asked to give out my true
name here in the US, I have to remember to not do that, and instead state my
name as it's transcribed to ASCII in my passport. One time I booked plane
tickets and wrote my last name as SCHRODER on the ticket, instead of SCHROEDER
as it says on the passport. This was a HUGE PROBLEM BECAUSE THE NAMES DON'T
MATCH.

Yes, but, look, they're both wrong, and they're close enough that surely you
can see they're the same?

My husband has three first names, the middle of which is his given name, and
one last name. For some reason when he applied for his EAD, the last letter of
his third first name fell off (I'm guessing character limit in some field in
some system), so when we was getting his SSN, there was a huge problem,
because again, THE NAMES DIDN'T MATCH!!! So it was just gonna take weeks
longer to receive it, presumably because some other human has to look at it
and ok it. There was also not enough space in the first name field, so he got
some of his first names moved to the middle name field instead. I'm sure this
will cause all sorts of fun and hijinks in the future if someone tries to
match the name kind by kind, instead of just the full name.

~~~
marvin
Have you played the game "Papers Please", where you work as a border control
guard and have incentives to turn people away for the smallest reason?

The rule that causes you trouble, _the name on the ticket must exactly match
the name on the passport_ , stems from this era.

------
300bps
I was thinking about this the other day. My last name is extremely rare; less
than 20 people in the world have it.

As such, I am completely unable to maintain any level of anonymity in the
world today. It's trivial to find anything I've been up to by using Google or
Bing. You can even see my entire family and what they've been up to and
there's no doubt they're my family because my last name is so rare.

I seriously considered changing my last name to Smith. I think it's better to
have nefarious people drown in a sea of false positives than it is to give
them pinpoint accuracy directly to me (as I have today) or few enough false
positives (as Stephen Law has) that they catch a lot of innocent people in
their wide net.

I actually know some people with the Smith last name. Every time they buy a
house, the title insurance company provides them a list of deadbeats with
their exact same name and they simply sign a form saying, "Not me" and their
transaction continues.

Imagine if they wanted to put John Smith or Joseph Brown on the OFAC list.
They'd never be able to.

~~~
harshreality
If you or anyone else wants to change names, make sure your new one isn't on
the OFAC SDN list, and don't pick a name from an ethnicity (non-oriental
asian, and perhaps african) that's more likely to end up on the list in the
future. That's one list you _can_ check.

[http://www.treasury.gov/resource-center/sanctions/SDN-
List/P...](http://www.treasury.gov/resource-center/sanctions/SDN-
List/Pages/default.aspx)

------
opensandwich
Previous sanctions data analyst here. At my previous bank I worked for they
follow a process like this:

1\. Screen by name and date of birth (sometimes only year of birth only) for
all lists (EU, US, Australia, etc); with some tolerance 2\. Manually match
against address, sex, etc

Now for some of these lists, depending on the vendor which is used, they may
also have information on where the person(s) were last seen (perhaps they're
from China and recently visited UK based on public information); not only
their country of residence. So this means, if you happen to have a birthday
sufficiently close to someone on the list (+-2 yrs) and they happen to be last
seen in the country you reside in, then they would have to do the whole manual
checking.

Now this seems like a lot of work, but when you consider things like
reputation risk of getting caught and the possible fines, banks would rather
screw over their own customer (or outright refuse to do certain transactions
to certain countries) than doing what is best for their customers.

For the other attributes which are available like sex, it is sometimes used,
but often for manual checking. Data is often too messy to have a viable real-
time solution for screening. It is often cheaper to get someone from India to
do it for you, rather than re-haul a whole database to have it done
"properly". This is the unfortunate reality.

~~~
daemin
And yet there have been many banks willing to money launder and deal in
illegal activities if the price (profit) is high enough. I guess ordinary
customers just aren't rich enough.

------
kiba
It seems that the governments try to keep coming up with new ways to punish
lawbreakers like drug traffickers without regard to the effect it has on the
larger society and the economy.

If you're a criminal or marked as such, you couldn't 1) keep your ill gotten
money, 2) make money from selling your stories about your criminal exploit, 3)
can't make legit money once you get out of jail since nobody hire felons, 4)
branded even more if you're a sex offender, 5) can't get on planes due to no-
fly list, 6) can't get sent money if you're on the treasury list.

All of these are of course, "well intentioned", but it does collateral
damages. If your name is even "Stephen Law", you can't get wired money. AML
laws forced banks to spend a shitload of money spying on people's finance that
would otherwise be spent on more productive activities. Oh, it disallow banks
and other money related services from forming, creating olipologies and
monopolies. People who aren't terrorists are now on the no-fly list for no
reason or because of procedural mistakes. Now they drive and die in motor
vechicle accidents. Felons cannot contribute to society or get because nobody
wants to hire them, so they became the underclass in societies and some of
them will turn back to criminal behaviors.

Obviously, there are measure worth implementing, but they must be judged not
on just preventing crimes, but also the cost to societies. Heck, some of these
measure aren't even effective, and wastes policing resource.

~~~
notahacker
It's worth pointing out the flip side of that cost-benefit equation, which is
that the constant irritation of Western restrictions on their freedom to spend
their ill-gotten gains is believed to be one of the main factors behind the
Burmese military junta's relatively recent acceptance of reform.

Arguably Myanmar's 60 million mostly impoverished people deserve as much
consideration as a pretty large number of innocent people with the name
Stephen/Steven Law.

~~~
CamperBob2
Sorry, but punishing me to get at the Myanmar junta isn't OK.

~~~
cmsmith
The entire nature of the social contract is based on the idea that punishing
you to make the world better is OK. You are punished in the form of taxes so
that the government can provide social security and foreign aid and military
intervention (independent of whether you individually support those actions).
You are inconvenienced in the form of DUI checkpoints to punish drunk drivers.

You have a couple of choices:

1: Decide that the net cost to living in civilization is worse than the
benefit, and go and live with some nomadic hunter-gatherers somewhere.

2: Vote to change policies you disagree with, and live with the ones that you
are in the minority on.

~~~
CamperBob2
Just out of curiosity (and no offense intended), how old are you?

------
zacinbusiness
People basically can't just "Google" me. Why? My name is Zac Brown. That's
already a pretty common name. But the musician pretty much shields me from
everyone.

Interesting side note:

I occasionally get email that is directed at that Zac Brown. Including a guy
asking if I would play a gig at their company retreat (I agreed to), a guy
asking about boat decals (I didn't like them), and a guy just looking to catch
up for old times sake (I informed him that I was the wrong guy but wished him
the best).

Somebody who works for the guy even added me on LinkedIn (I accepted because
why not).

~~~
jrockway
People occasionally mail me asking what sort of Japanese rock music they
should buy, because my domain is jrock.us. I just search on Amazon and
recommend whatever seems popular. (Does Houkago Tea Time count as J-Rock?
Probably not. I guess I should change my name to animesong.)

------
jey
This is unlikely to get resolved until one of these "terrorists" adopts the
name of a Member of Congress as an alias. Until then, this ham-fisted policy
is for _your_ protection.

~~~
e1ven
Unfortunately, even that is not sufficient to overcome institutional
bureaucracy -

[http://www.washingtonpost.com/wp-
dyn/articles/A17073-2004Aug...](http://www.washingtonpost.com/wp-
dyn/articles/A17073-2004Aug19.html)

~~~
dtf
Also Rep. John Lewis.
[http://edition.cnn.com/2004/ALLPOLITICS/08/20/lewis.watchlis...](http://edition.cnn.com/2004/ALLPOLITICS/08/20/lewis.watchlist/index.html)

------
timrogers
The full list is pretty incredible.
[http://www.treasury.gov/ofac/downloads/t11sdn.pdf](http://www.treasury.gov/ofac/downloads/t11sdn.pdf)

~~~
unabridged
Just with a brief scan it looks like over 90% of the names are arab, and it
seems to cover all of the common names. Does this mean a large percentage of
arab people cannot send money/packages involving the US?

------
omarali
I've had rebate cards blocked because my name "Omar Ali" matched the alias
"Ali Omar" of someone who is in detention in the Philippines but still on this
list
[http://www.un.org/sc/committees/1267/AQList.htm](http://www.un.org/sc/committees/1267/AQList.htm)

Adding a letter to my last name was enough to not match anymore.

------
kevinalexbrown
I don't think this represents a change in government mentality. Probably more
a shift in technical capability. Before, requiring every bank and merchant to
check every order against a list would have been onerous. Now, it's fairly
easy.

I find it curious how so many specific powers that have been granted to
government were allowed not because they were universally acceptable, but
because they were impossible to enforce widely.

As automatic monitoring and enforcement get easier, I suspect we'll have a
more robust debate on what types of laws are acceptable, because there will be
so little room for leeway.

~~~
stefantalpalaru
> more a shift in technical capability

This is not a recent development. We've had name based no-fly lists[1] since
at least 2001.

[1]:
[https://en.wikipedia.org/wiki/No_Fly_List](https://en.wikipedia.org/wiki/No_Fly_List)

~~~
cookiecaper
I think his definition of recent is inclusive of 2001. He seems to be
referring to the time period before powerful commodity computer systems were
easily available and deeply integrated into every aspect of life, probably
like '85 on back. For some edgy cases this could protrude into the mid-90s,
but I don't see it going any later.

------
mcv
The workaround for shipping goods seems easy: put a different name on the
shipment. As long as the address is correct, it should be fine. Will US
customs check the names of everybody who is officially registered at that
address in the UK? I suspect not.

And if it has to be a real name, just put the name of your spouse, friend or
family member on it.

Of course all of that just illustrates how utterly ineffective such an OFAC
blockade is.

~~~
vacri
If the postal carrier holds the parcel for any reason, that can backfire, as
they usually need ID for a pickup. A not insurmountable problem, but annoying.
I once shipped a parcel to a forum acquiantaince under his handle, and he had
a mild problem proving to the post office that he was the guy at that address.

------
qbproger
It's so easy for this mistake to happen and inconvenience the wrong person. It
seems all they check is your name. What happens if they change their name?
Does the entire hassle go away?

------
juliendorra
It can go very far, sadly: I found the story of a guy killed because he was
homonymous when I wrote [http://ils.sont.la/post/is-your-name-web-
ready](http://ils.sont.la/post/is-your-name-web-ready) some time ago.

Homonymity is never really an asset: you don't control it as you can control
anonymity and pseudonymity.

------
fredgrott
Now imagine the increases in difficulty when we deal with non-Latin names,
which often have 2 to 3 ways of being translated to Latin name schemes.

This is why any list does not work as its non-specific whereas if we get
specific about metadata that is combined with the name than we have an
effective block list instead of a government cluster fuck.

~~~
thebooktocome
Check out pages 304--308 in the list linked elsewhere. All devoted to one guy
with about twelve romanizations.

------
wobbleblob
My dad, who travelled the world for his work, was denied entry to the USA in
the 60's because he had the same surname, initials and DOB as a local member
of the communist party.

------
ChuckMcM
The silly part here is that while it is a pain, it is certainly possible to
change your name legally. And in so doing "vanish" from the list. Of course
regular folks won't go through the trouble but terrorists will ...

~~~
scotty79
The silly part is the whole thing. You may give your friends name when
ordering a package.

~~~
ChuckMcM
I've not had good success with this. Too often the delivery service really
really wants to use the name for actual delivery. However it would be entirely
possible to start receiving mail for your fictional and non-blacklisted friend
to train up the various delivery people. In the article there was also an
issue with bank transactions and using an arbitrary name for those is
generally frowned upon.

~~~
scotty79
I think that when you are a terrorist you also can have actual friends that
can receive a package for you. Blacklisting name and surname gives no security
apart from places where you personally must produce your own ID. It has merit
when checking passport on the border but none when you decide whether to ship
a package to another country or even to receive money.

------
uiri
Anyone else notice that "Peter Griffin" is on this list?

[https://ofac.data-list-search.com/Entities/ByName/peter-
grif...](https://ofac.data-list-search.com/Entities/ByName/peter-griffin)

------
lilsunnybee
This scattershot approach to inconveniencing suspected criminals seems similar
to how the US conducts drone strikes: it doesn't matter how much collateral
damage you cause, as long as you're targeting the right guy.

------
ck2
Imagine the hell they are going to go through if they ever try to visit the
US.

~~~
kirab
As if they were even allowed to.. :(

------
vonskippy
Easy solution, setup company name, use company name for all package shipments,
wire transfers, checks, etc. Should solve everything but the travel.

------
adambom
Am I the only one who thought, "Maybe he is the Burmese Stephen Law, and this
is just a cover story?"

~~~
rwmj
Yes. Even if he was, how is making bank payments less convenient helping? If
he's the nefarious Stephen Law, discovered living in the UK, wouldn't it be
better to go around to his address and arrest him?

------
tnuc
Why doesn't he just get stuff sent to Steve Law.

Problem solved.

~~~
lstamour
For the same reason presumably that the current law is successful: Certain
uses require legal names.

Otherwise, why have the check at all?

~~~
anigbrowl
Stephen M. Law (or whatever his middle initial is).

It's cack-handed bureaucracy of course but this is like saying that companies
occasionally sending bills to dead people means that computers are a bad idea.
This is the price you pay for automation.

------
DannyBee
"email letter to OFAC "

I really hope he at least sent a real letter.

~~~
tedivm
A real letter probably wouldn't have made it through customs ;-)

~~~
DannyBee
;) "We destroyed a letter from suspected terrorist Stephen Law before it
reached its intended target"

------
joshfraser
Names should never be used as primary keys. I am amazed that our government
does not understand this or simply doesn't care. I would even question whether
we should be imposing these types of sanctions in the first place -- feels
like punishment without trial.

~~~
dinkumthinkum
I'm not defending it but I don't think they are using then as primary keys.
Imagine if they did not look at the names or have lists at all, and something
happens involving someone with a name of a known terrorist. People would cry
"why doesn't the government have a list, are they too stupid to know how to
search databases?"

------
jrockway
What a stupid system. If customs is blocking packages, can't the real Stephen
Law just have it mailed to Steven Law or Foo Bar or anything?

------
fosap
I think the word for this is "Kafkaesque".

------
NAFV_P
In double entry this could be termed an _error of commission_ , four entries
are required for correction.

------
joesmo
It's amazing with all the spying that the US Government can be so incredibly
stupid.

------
johnchristopher
Couln't he set up an alias of some kind to manage his earnings and
international money related stuff ?

It seems common for criminals to get fake ID and associate it with their bank
accounts, etc. So it might be an (illegal?) solution.

------
judk
Treasury is Breaking the Law

------
linuxhansl
The NoFly list for banks.

------
nctalaviya
Thanks for the update

