Configuring Address Comparison

The main function of sanctioned party list screening in Compliance Management is to compare business partner addresses with sanctioned party list entities. If the system identifies a match between a business partner address and a sanctioned party list entity, it blocks the business partner in question. Replicas of feeder system documents that contain a blocked business partner are also blocked. Any documents that existed before the screening was run must be checked again.

When configuring sanctioned party list screening, you must first decide whether the address comparison is to take place immediately after the transfer of a partner master record or document (synchronously), or at a later point in time that can be determined on an individual basis (asynchronously). For document screening, you make this decision at item category level, and for master data screening you make it at business partner role level.

In synchronous screening, the system does not always run a full comparison of the business partner addresses with all sanctioned party lists entities. The system only checks the status of the business partner (blocked or not blocked) and then compares the partner addresses that have changed in the feeder system document with the sanctioned party list entities.

If a business partner is already blocked as the result of previous sanctioned party list screening, all new documents for this partner are also blocked automatically.

To define the screening mode for business partners in Customizing, choose SAP Global Trade Services, edition for SAP HANA → Compliance Management → Sanctioned Party List Screenings → Activate Business Partner at Business Partner Function Level. In the Time of SPL Check field, select the Synchronous - When Object Is Updated indicator if you want the master data to be screened synchronously. For the asynchronous screening, which is useful during the initial load, select the Asynchronous - When Function Is Called indicator instead.

The indicator in the Type of SPL Block field is only relevant for asynchronous screening. If the Process is interrupted - system removes block indicator is set, SAP GTS blocks new or changed business partners until asynchronous screening as a precautionary measure.

You decide on the screening mode when activating item categories for sanctioned party list screening (menu path: SAP Global Trade Services, edition for SAP HANA → General Settings → Document Structures → Activate Item Categories for Application Areas). In the dialog structure, open the Activation for Sanctioned Party List Screening folder and select the required item category. In the SPL Screening Time field, select the appropriate screening mode.

Sanctioned party list screening based on the standard SAP GTS search algorithm consists of three substeps:

1. Determining the search terms that are relevant for comparison from all the search terms for an address.

2. Calculating the percentage match for each relevant search term.

3. Calculating the percentage match for each address element (for example, for the name).

As a first step, SAP GTS checks each search term to see whether it is identical to or contained in its comparison term. Based on the settings in delivery Customizing for sanctioned party list screening (control settings for legal regulation SPLUS), the comparison of search terms is carried out from the perspective of the sanctioned party list entry only (Scope of Screening area, Search Strategy field, SPL Entry Searches in Address Entry indicator). If you want SAP GTS to compare business partners and sanctioned party list addresses in both directions when selecting the relevant search terms, set the indicator A (SPL Entry Searches in Address Entry and Vice Versa) in the Search Strategy field instead.

In the example in figure, the business partner address of customer 10999 (California Motomarket Ltd.) was compared, among others, with the sanctioned party list entries 30540 (Omar Carillo), 36190 (Mark Belinic), and 36370 (Ali Chan). SAP GTS already sorted out individual name components when indexing the addresses. Of the name components contained in the comparison index, only the terms MOTOMARKET, CALIFORNIA, OMAR, MARK, and ALI qualified for the second screening step from the first screening step. The tables "Business Partner Address" and "Sanctioned Party List Entries" provide an overview of this filtering.

In the second screening step, SAP GTS calculates the percentage match of the search terms. The system first counts the characters that make up the terms. It then determines the number of identical letters. At the end of the screening step, the system divides the number of matching characters by the total number of characters in the comparison term and multiplies the result by one hundred to calculate the percentage match.

Table "Calculation of Percentage Match (Example 1)" contains an example of this calculation.

The term "Motomarket" consists of 10 characters and the term "Omar" consists of four characters. Four characters are the same in both terms. SAP GTS divides the number of matching characters by the total number of characters of the comparison term "Omar" and multiplies the result by 100. This calculation results in a hundred percent match between the two terms.

In the second example, SAP GTS divides the number of matching characters by the total number of characters of the comparison term "Motomarket" and multiplies the result by 100 again. The match percentage is now only 40.

In the third screening step, SAP GTS divides the number of matching search terms of an address element by the total number of search terms for this element. When comparing "California Motomarket" and "Omar Carrillo", SAP GTS calculates a match percentage of 50: the names of the business partner and the sanctioned party list entry each consist of two terms. One term matches ("Omar").

According to the delivery Customizing settings for sanctioned party list screening, a 50 percent match of the name is sufficient to identify the business partner with the sanctioned party list entry.

For the search term US – the country code in the business partner address – SAP GTS assumes a hundred percent match, even though the address of the sanctioned party list entry does not contain any country codes. In the case of sanctioned party list entries without a country specification, the system always assumes that the listed person can be located anywhere. According to the worst-case principle, the percentage match is therefore 100 for each country.

Sanctioned party list screening is based on a calculation of the percentage match of screening-relevant address components. If this percentage is above a threshold value defined in the configuration, SAP GTS assumes that the business partner may have the identity of the listed person.

To calculate the percentage match of the screening-relevant address components, SAP GTS splits the addresses of business partners and sanctioned party list entries into search terms and then groups these search terms in comparison indexes. You use the programs /SAPSLL/SPL_CREATE_SEARCHTADRC (business partner) and /SAPSLL/SPL_CREATE_SEARCHTERMS (sanctioned party list entries) to generate comparison indexes. You can also execute both programs online using the transactions Create Comparison Index for Business Partner (transaction code /SAPSLL/SPL_STBP) and Create Comparison Index for Sanction List (transaction code /SAPLL/SPL_ST01) respectively.

If you index a business partner address or sanctioned party list entry online, you can display the result in an overview. This function is also useful when testing the configuration.

Example of a business partner address in the training system:

Log of the indexing of this business partner address:

SAP GTS has indexed the business partner address at the level of the self-defined legal regulation ZSPEU (Personal sanctions - EU). List type DPLEU (Denied Persons Lists (EU)) assigned to the legal regulation has a minimum length of three characters for the address element "Name". The name components "No" and "1" are therefore eliminated before indexing. The system does not include the company extension "Service" defined as an exclusion text in the index either.

SAP GTS eliminates ligatures when setting up the index if it does not explicitly provide a different configuration for the comparison procedure in Customizing. In addition, all lowercase letters are automatically converted to uppercase letters. Different spellings of address components are aligned in this way.

You influence the structure of the comparison indexes by configuring a comparison procedure that is defined in Customizing and assigned to the legal regulation for sanctioned party list screening (menu path: SAP Global Trade Services, edition for SAP HANA → Compliance Management → Sanctioned Party List Screenings → Define Comparison Procedure → Define Comparison Procedure for Address Comparison). For some settings, you can also access this comparison procedure using transaction Manage SPL Comparison Terms (transaction code /SAPSLL/VC_CMPAS).

It usually makes sense to include common components of the company, such as "Corporation" or "Ltd" as exclusion texts in the comparison procedure. Often, these name components significantly increase the number of obviously incorrect hits in sanctioned party list screening, without making a significant contribution to the identification of a listed person.

You can use alias terms to replace different forms of the same name, for example, "Tom" as a short form of "Thomas". In the Normalization folder, you can replace individual letters or sequences of letters with other letters, for example, the letter sequence "ue" with the umlaut "ü".

The characters collected in the Delimiter folder, which can separate name and other address components, are crucial for the indexing of business partner addresses and sanctioned party list entries. The system interprets the hyphens in the address of the business partner in the example shown ("Bertolt-Brecht-Strasse") as separators, and splits the street name into three search terms (BERTOLT, BRECHT, and STRASE).

After each change to the comparison procedure or another Customizing setting that controls sanctioned party list screening, and after each upload of a new or updated list, you have to regenerate the comparison indexes. The comparison index for the sanctioned party list entries must also be aggregated (transaction Aggregate Comparison Index of Sanction Lists, transaction code /SAPSLL/SPL_ID01). Knowledge Base Article (KBA) 2074620 describes the procedure.