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16.19 Sanction Screening

N 35/2018 STA
  1. 16.19.1Appropriate systems must be introduced for real time screening, as part of the KYC process, on all parties involved in a transaction against all applicable sanction lists (i.e. the UN sanction lists and the names contained in the ‘search notices’/‘search and freeze notices’ issued by the Central Bank);
  2. 16.19.2Written processes and procedures for the escalation and clearing of potential sanction matches must be introduced;
  3. 16.19.3The logs/records related to the clearing of potential sanction matches must be available in the system for five (5) years;
  4. 16.19.4The UN sanction lists must regularly and automatically be updated within the Point of Sale/computer systems of the Licensed Person preferably without any manual intervention. Addition and deletion of names in the UN sanction lists must be immediately updated by the Licensed Person as and when such changes are announced by the UN Security Council. Appropriate logs must be maintained in the system to confirm such updates;
  5. 16.19.5In case the name of a customer is an exact match (i.e. a true match) to a name or names in the UN sanction lists or ‘search and freeze notices’ issued by the Central Bank, the Licensed Person must immediately freeze the funds of that customer. The Licensed Person must immediately inform the FID along with the details of the customer and the amount of funds frozen for further instructions. The Licensed Person must not defreeze such amounts without obtaining a confirmation from the FID;
  6. 16.19.6In case the name of a party to a transaction is an exact match to a name or names in ‘search notices’ issued by the Central Bank, the Licensed Person must immediately follow the instructions provided in such notices; and
  7. 16.19.7Sanction screening must be applied in the below cases:
    1. a)In the case of foreign currency exchange transactions, the customer’s name must be screened against the sanction lists;
    2. b)In the case of money transfer transactions, the Remitter’s name and Beneficiary’s name as well as the name of beneficiary bank must be screened against sanction lists;
    3. c)Where the transactions are conducted by a legal entity, the name of the authorised person who carries out the transaction (i.e. the representative) must be screened against sanctions lists in addition to the name of the entity and its Ultimate Beneficial Owners. The Licensed Person, where applicable, must also comply with Paragraph 16.19.7 (b) of this Chapter; and
    4. d)The Licensed Person must also comply with the sanction screening requirements, in the case of third party transactions, as required by Paragraph 16.14 of this Chapter.