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It's Not Your Engine. It's Your List.

Clean, context-rich PEP control lists are the only scalable way to cut false positives.

·Pergamon Labs·8 min read

It's Not Your Engine. It's Your List.

Clean, context-rich PEP control lists are the only scalable way to cut false positives.


Real talk: your name isn't unique

Unless you're literally named "X Æ A-Xii" (Elon Musk's child's name), your name isn't unique. Screening engines see millions of name look-alikes; that's why you need other identifiers—DOB, jurisdiction, role dates, addresses, and well-structured aliases—to triangulate who you actually are and cut false positives.

TL;DR

Upgrade to clean, context-rich, time-bounded PEP data and watch false positives drop—without torturing thresholds.


Engines are smart—lists must be smarter

Modern screening stacks blend fuzzy matching, phonetics, transliteration, nickname mapping, and name-order logic to estimate match probability. What they can't do is invent context your list doesn't supply.

  • No DOB? Larger candidate sets and more noise.
  • No jurisdictions? More cross-border overlaps.
  • No role dates? Yesterday's official pollutes today's matches.

Control list quality > endless retuning.

Drake meme showing preference for better control list data over retuning models
Drake meme showing preference for better control list data over retuning models

False Positive Rate vs PEP Control List Richness

Richer PEP records (DOB, role dates, jurisdictions, aliases) shrink the candidate set before scoring.

False Positive Rate vs PEP Control List Richness chart
False Positive Rate vs PEP Control List Richness chart

Reality check: when lists are garbage, FPR can hit 100%

We've seen programs where the upstream PEP source was so poor that false positives hit 100%—every single alert was junk. That's not an engine problem; that's a list-quality problem.

Key point: Name-only, undated roles, missing jurisdictions, and absent DOBs create candidate sets so broad that precision collapses. No amount of threshold tweaking fixes missing context.


Regulatory reality: you can't turn off PEP screening—so do this

  1. Upgrade the control list: full DOBs, role start/end dates, role jurisdictions, structured aliases, RCAs, and source lineage.
  2. Time-bound roles: explicitly retire signals when a term ends to avoid "forever PEP" matches.
  3. Boost precise matches: give higher weight to role-dated + DOB-confirmed candidates; de-emphasize name-only fuzz.
  4. Delta updates: ingest new appointments quickly and capture exits—yesterday's data shouldn't pollute today.
  5. Analyst feedback loop: capture dispositions (TP/FP) to refine aliasing and edge-case heuristics in the list.

Bottom line: compliance stays on; noise goes down; analysts focus on real risk.


"100 Men vs 1 Gorilla" simulation (100,000 clients with full CIP)

We compared Pergamon Enriched Lists (DOB, role dates, jurisdictions, aliases, sources) to a Legacy name-heavy list (DOB 50%, address 50%, sources 15%). Assumptions: true PEP prevalence 0.1%, non-PEP name-collision baseline 4%, and stricter alerting when context is present.

MetricPergamon Enriched ListsLegacy
Alerts per 1K1.1432.87
False positives (% of alerts)14.0%97.3%
Precision (TP / Alerts)85.98%2.74%
Recall (TP / True PEPs)98.00%90.00%
TP (of 100 PEPs)98.090.0
FP per 1K0.1631.97

Data note: Name-collision baselines calibrated using Statistics Canada's 2021 Census first-name frequencies. Higher concentration → higher collision risk when DOB & role dates are missing.

Visual Comparison

The difference is stark when visualized:

Alerts per 1K comparison
Alerts per 1K comparison
FP % of alerts comparison
FP % of alerts comparison

Math & Validation Appendix

When you have to show the proof and the numbers actually add up.

Math calculations
Math calculations

Simulation math

TPₛ = N · π · rₛ
FPₛ = N · (1 - π) · (p_name-coll · p(alert|collision)ₛ)
Alertsₛ = TPₛ + FPₛ
Precisionₛ = TPₛ / Alertsₛ
FP%ₛ = FPₛ / Alertsₛ
Alerts per 1k = Alertsₛ / (N / 1000)
FP per 1k = FPₛ / (N / 1000)

Sensitivity (name-collision = 2%, 4%, 6%)

Name-collisionAlerts/1k (Pergamon)FP % (Pergamon)Precision (Pergamon)Alerts/1k (Legacy)FP % (Legacy)Precision (Legacy)
2%1.067.5%92.46%16.8894.7%5.33%
4%1.1414.0%85.98%32.8797.3%2.74%
6%1.2219.7%80.34%48.8598.2%1.84%

The Bottom Line

Change my mind meme: It's not your screening model, it's your control list
Change my mind meme: It's not your screening model, it's your control list

"It's not your screening model. It's your control list." — change my mind.


© 2025 Pergamon Labs — Context-first PEP control lists.