Compliance requires name matching: for instance, to match customers against sanctions and PEP lists. Unfortunately, the name of a single person can be spelled in many different ways. Hence, a decision has to be made whether matches of only very similar names should be verified,or matches of less similar names. In the former case, we may miss relevant matches and in the latter, we may get too many matches.

risk matching

Considering all relevant matches, the portion of matches eventually found by the name matching is called recall. A high recall minimizes the risk of missing relevant matches. In all matches found by the name matching, the portion of relevant matches is called precision. A high precision minimizes the risk of too many verifications.

risk matching2

A 100% recall and precision would be desirable, but is impossible since recall and precision are mutually conflicting goals. Hence, a balance between recall and precision implies a trade-off between two different risks. Finding the optimal trade-off, or equivalently finding the optimal-name matching configuration, is difficult, since it depends on different aspects, such as business strategy and risk aversion.

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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