Sanctions screening sounds like a lookup: is this name on the list? In practice it is a matching problem, across alphabets, spellings and deliberate disguise. Get it wrong one way and a sanctioned party passes. Get it wrong the other way and analysts drown in false alarms.

This piece walks through how Saolix Eagle decides whether a name matches, step by step.

Step 1: make names comparable

Before any comparison, Eagle normalises the name. Accents and diacritics are stripped, and names in Cyrillic, Arabic, Chinese, Korean and Japanese are transliterated into Latin characters using established, internationally recognised romanisation systems.

Eagle also folds homoglyphs: characters from other alphabets that look identical to Latin letters. A Cyrillic "а" typed in place of a Latin "a" is an old trick for slipping past exact-match systems. After folding, both read the same.

Step 2: an exact match on identity, when you have one

When a screening includes an identifier, such as a date of birth or a document number, and it matches a listed party, that is the strongest signal there is, and the verdict is FAIL.

A name alone is never enough for that. Many people share names with listed parties, so a name-only match is weighed like any other.

Step 3: compare and score

Eagle compares the name with every listed party and scores each candidate with a layered combination of well-established, industry-standard techniques:

  • Lexical similarity, for names that are spelled almost the same
  • Fuzzy matching, which tolerates typos, missing letters and reordered names
  • Phonetic matching, which recognises names that sound alike across very different spellings

The scoring is designed so a disguised name cannot slip through by scoring poorly on a single measure.

Step 4: a verdict from configured thresholds

Configured thresholds map the combined score to one of three verdicts. Administrators can change them, but only with a second person's approval:

  • PASS: no meaningful match
  • REVIEW: a possible match for an analyst
  • FAIL: a strong match

With one important condition. A FAIL is capped at REVIEW unless a date of birth or an identifier was supplied with the screening. A name that looks exactly like a listed name goes to an analyst. It is not blocked automatically.

A name that looks like a listed name goes to a person. It is not blocked by a score.
The Eagle matching pipeline: normalise and transliterate, identity check when identifiers are supplied, compare and score with layered industry-standard techniques, then a verdict from configured thresholds with uncorroborated fails capped at review. HOW EAGLE MATCHES A NAME Normalise5 scripts · homoglyphs Identity checkDOB · document no. Compareindustry-standard Scorelayered · deterministic VerdictPASS · REVIEW · FAIL A FAIL WITHOUT A DATE OF BIRTH OR IDENTIFIER IS CAPPED AT REVIEW
Every step is deterministic: the same name, the same lists and the same rules produce the same verdict.

Which lists, and how fresh

Eagle maintains its registry from the major sanctions sources, including the US OFAC SDN list, the UN consolidated list, the EU financial sanctions list and the UK Sanctions List, along with further lists and politically exposed persons. Each list update is versioned, and delisted entries are removed. Every interactive screening records which version was in force, and how old each list was at that moment.

Where AI fits

Nowhere in the steps above. The verdict is produced entirely by the deterministic pipeline. Eagle's copilot works afterwards, helping the analyst understand a REVIEW: explaining why the names matched and what to check next. It can never turn a REVIEW into a clearance on its own. We explain that line in The determinism boundary in practice.

You can screen names yourself in the Eagle Simulator.