Sanctions name screening

Institutions shall screen customers, beneficial owners, counterparties and transactions against OFAC and other applicable sanctions lists in real time.

Financial institutions may not keep anonymous accounts or accounts in obviously fictitious names and must, by a principle set out in law, undertake customer due diligence when establishing a business relationship, carrying out an occasional transaction above USD or EUR 15,000 or a payment or value transfer covered by INR.16, when money laundering or terrorist financing is suspected, or when they doubt previously obtained identification data: identify and verify the customer from reliable independent sources; identify the beneficial owner and take reasonable measures to verify that identity, understanding the ownership and control structure of legal persons and arrangements; understand and where appropriate obtain information on the purpose and intended nature of the relationship; and conduct ongoing due diligence and transaction scrutiny consistent with the customer's profile including, where necessary, the source of funds. The extent of each measure follows a risk-based approach; verification takes place before or during establishment of the relationship, or as soon as reasonably practicable after it where risks are managed and business would otherwise be interrupted; an institution that cannot complete CDD does not open the account or perform the transaction, or terminates the relationship, and considers a suspicious transaction report; the requirements apply to new customers and, on materiality and risk, to existing ones. The Interpretive Note sets the risk-based approach, enhanced and simplified measures, the specific measures for legal persons, arrangements and beneficiaries of life insurance, reliance on prior verification and the timing rules.

Countries implement targeted financial sanctions regimes giving effect to the UN Security Council resolutions on terrorism and terrorist financing, freezing without delay the funds and other assets of persons and entities designated by or under the authority of the Security Council under Chapter VII (resolution 1267 and successors) or designated by the country under resolution 1373, and ensuring that no funds or assets are made available to or for their benefit; the Interpretive Note sets the designation authorities and procedures, the freezing obligations without delay and without prior notice, the prohibitions, the communication of designations, the reporting duties of institutions, the delisting and unfreezing procedures and access to frozen funds for basic expenses.

In processing payments or value transfers, financial institutions take freezing action and do not conduct transactions with persons and entities designated under the UN Security Council resolutions on terrorism and terrorist financing (resolution 1267 and its successors and resolution 1373) and on the financing of proliferation of weapons of mass destruction; the Recommendation does not prescribe whether or how message information is screened against sanction lists, since different mechanisms can achieve compliance with targeted financial sanctions.

Screen customers and transactions against DFAT consolidated list and UN sanctions to comply with autonomous sanctions.

The organization must operate controls that block or reject transactions involving sanctioned persons or property and report blocked or rejected transactions to OFAC within required timeframes.

Per OFAC: Policies and Procedures + Transaction Screening + Interdiction and Escalation + Recordkeeping (5 years per OFAC).