2.4. Internal Controls
Effective from 4/7/2021Internal controls are the mechanisms, rules, and procedures implemented to help ensure the integrity and effectiveness of an LFI’s SCP. As required by Cabinet Decision 74, LFIs must have appropriate internal controls in place, including the most recent publication of Targeted Financial Sanctions of the UN Consolidated List and the Local Terrorist List. Accordingly, LFIs must maintain strong and clear internal controls that ensure the effective implementation of their SCP, including policies, procedures, processes, and systems.
| • | LFIs should document how their processes and systems are configured in order to demonstrate that their configuration is reasonably expected to detect and manage the specific sanctions risks to which the LFI is exposed to and ensure transparency of any system limitations or risk-based decisions that the screening controls are not designed to detect.4 | |||
| • | LFIs should establish a mechanism to ensure that, upon learning of a weakness pertaining to its SPC compliance, immediate and effective action is taken to identify compliance gaps and their root causes, including all program-related software, systems, and other technology, and remediate them by implementing systemic solutions to reduce the chances of future failures. | |||