Name Matching & Revision (Part 4)

Our last post discussed how to minimize false negatives to reduce risk and false positives to conserve resources. Yield refers to the percentage of high-risk customer relationships that are discovered through name matching. Ideally, this figure is 100%. As explained previously, however, this is not realistic. Precision refers to the percentage of matches that are truly high-risk. Here, too, the ideal figure is 100%, but this is not achieved in reality. This fourth part discusses practical ways to manage yield and precision.

Onboarding is generally a one-time occurrence. So, in order to minimize risk, more work is often put in at this stage. In other words, the focus during the onboarding phase is on yield.

Periodic checks must be carried out more frequently due to sanction regulations requiring immediate reporting. Such checking consumes more resources, resulting in a greater focus on precision. The greater the level of precision, the lower the number of false positives.

The eCPM system from Eurospider uses a “Very Similar” setting to achieve good precision. The “Less Similar” setting achieves good yield. Depending on the quality of the customer data and the risk profile of the financial intermediary, the “Similar” setting may be more useful depending on the particular case.

Data Protection Act

The Swiss Data Protection Act underwent a complete revision in 2020, and its new version took effect on September 1, 2023, along with the new Data Protection Ordinance (DPO). The revision itself is complete, but its practical application continues to evolve. The topic of AI is particularly relevant: On May 8, 2025, the FDPIC confirmed that the DPA is technology-neutral and applies directly to all AI applications. In practice, this means, among other things, that users must know whether they are interacting with AI (transparency requirement, Art. 19), and that a data protection impact assessment is mandatory in cases of high risk—such as profiling or facial recognition (Art. 22). The Federal Office of Justice (FOJ) is drafting a consultation document on AI regulation to be completed by the end of 2026. With this, Switzerland will implement the Council of Europe's AI Convention.

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