Practising Law Institute Best Practices to Minimize the Risk of Money Laundering OFAC Lists and Due Diligence Ussama Binladen or Osama bin Laden? Understanding.

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Practising Law Institute Best Practices to Minimize the Risk of Money Laundering OFAC Lists and Due Diligence Ussama Binladen or Osama bin Laden? Understanding Middle Eastern Naming Conventions James R. Richards, B.Comm., LLB BSA Compliance Officer Director, Financial Intelligence Unit FleetBoston Financial Group, Boston, Massachusetts Presentation for the Practising Law Institute New York, New York January 23, 2002

The Arabic language is divided into three groups: Classical written Arabic (used in the Koran); Modern Standard Arabic (MSA, a modern version of classical written Arabic used in newspapers and textbooks); and Spoken, colloquial, or dialectic Arabic The Arabic alphabet consists of 16 characters which, when combined with one to three dots placed above, below, or beside a character, form 28 signs or letters. The Arabic alphabet is made up entirely of consonants...

Therefore, Mohammed is written in Arabic as mhmd... That is why we have so many different spellings of Mohammad, Mohamad, Mohammed, Muhammed, etc... Arabic words are written and read right to left, top to bottom. Arabic numbers are written left to right. The first three letters of the Arabic alphabet are ‘alif, baa’, and taa’. alif-baa-taa – along with “alpha beta” from ancient Greek, give you the origins of the english word “alphabet.”

Why are there different spellings for certain words? eg., Koran …. Quran eg., Osama …. Ussama eg., Saddam Hussein …. Tsaddam Hussein There are two systems of converting Arabic into English, known as “systems of transliteration” Almost all nouns and the ten forms of verbs are built around a stem or root or three consonants … called the “triliteral root system” The root “s l m” means “peace” … Islam, Muslim, Salaam

The name Mohammad Al-Ghamdi has at least 56 different spellings And none of those 56 will enable you to identify the person! Arabic names must have 4 parts - first name, two generational names, and a family, village, or descriptive name... Osama bin Laden? Or Ussama bin Mohammad bin Awad bin Laden He is known as Ussama, son of Mohammad, grandson of Awad, great-grandson of Laden

Abu, Ibn or bin, and Abd. Three key Arabic “names” … These words mean Father, Son, and Slave, respectively: Abu Ibrahim means Father of Abraham … Ibn Mohammad means Son of Mohammad, and Abd Allah or Abdullah means, literally Servant of God Classical Middle Eastern names require at least four components. These are broken down into six general categories...

1. Honorific Name (kunya or agronem) - as the father or mother of. Often reserved for the eldest son. eg., abu Da'ud (Father of David) or Umm Salama (Mother of Salama). 2. Personal Name (ism) - common: Muhammad (Mohammed), Ibrahim (Abraham), Hasan, Ahmad. Rarely used socially, then only if the person is famous. 3. Descriptive Name (lakab or cognomen) - usually religious, relating to nature or some admirable quality the person has or would like to have. eg., 'Abd Allah (Servant of God, often written Abdullah), Harun Al-Rashid (Aaron the Rightly-Guided).

4. Patronymic Name (nasab or lineage) - denotes the pedigree, as the son or daughter of a certain person. eg., ibn 'Umar (son of Omar) or commonly spelled "bin" Umar (as in Osama bin Laden). Usually limited to three generations. 5. Geographical or Tribal Name (hisba or nisba) - derived from the place of residence or birth or origin of the family by using the prefix al or el and the suffix i, eg., Yusaf al-Isfahani (Joseph of Isfahan) or Ahmed Alghamdi (Ahmed of the Tribe of Ghamd). 6. Occupational Name or Nickname (laqab) - derived from a person's trade or family history, eg., Muhammad al-Hallaj (Mohammed the Cotton Weaver) or by a nickname bestowed posthumously or during the person’s lifetime, either as an honorific name or an insult or distinguishing feature.

One of the first OFAC lists includes the name Abdullah Ahmed Abdullah with an alias “Abu Mariam.” Mariam is a female name; adding Abu makes the alias into an insult, as a man will never be called “Father of” a girl. To do so is to insult the man, implying he is effeminate or weak A great name using the laqab, or nickname is … Amr ibn Bahr al-Basri al-Jahiz, a famous Muslim poet. Known to most simply as al-Jahiz, his name actually means “Amr, son of Bahr from the Basr region, also known as Amr The Google-Eyed!”

Conclusion … Any reasonable effort to run OFAC and Control Lists against customer and transactional databases requires at least a basic understanding of the types of names you are required to search.