Sanctions are prohibitions and restrictions involving financial activities through financial services. These can be placed on entire countries or against individuals and entities that are deemed to be engaged in breaches of international law, human rights abuses or other forms of crime.
First AML conducts Sanction screening through our service provider Comply Advantage on all individuals verified via the First AML Platform. Comply Advantage generates a report for any individuals whose details match those of an individual or entity sanctioned; these reports are accessible via the First AML platform.
This article will outline how Sanction screening checks surfaced in the platform, what the results mean, and how to further review any matches or possible matches.
TABLE OF CONTENTS
- How to determine whether a possible match is true or false
- Determining the next step
- Possible Match - False
Why are Sanction Screenings required?
All reporting entities and relevant persons are required to screen for sanctions as part of their obligations under the AML regulations and national law.
Screening should be undertaken as part of an effective Financial Crime Compliance (FCC) programme, to assist with the identification of sanctioned individuals and organisations, as well as the illegal activity to which FIs may be exposed. It helps identify areas of potential sanctions concern and assists in making appropriately compliant risk decisions.
First AML conducts sanction screenings on all individuals verified via the First AML Platform. These checks are surfaced in the individual profile to be presented with one of the following results:
- Match (Red Flag) = Positive Sanction match identified
- Possible Match (Orange Flag) = Match identified, First AML have been unable to determine whether the match is positive or negative
- No Match (Green Flag) = No Sanction match identified
What is a Match?
A Sanction Match means that this individual is confirmed to be on a sanctions list, international or national watchlist, warnings and regulatory enforcement list or a fitness & probity list.
What is a Possible Match?
A Possible Sanction Match means that some of the individual's details (e.g. name, dob, country) match with an individual who is on a Sanction watchlist, however, we have been unable to determine a positive match. The possible match flag is to show that some details have matched however there appear to be discrepancies in information, spelling, location, and/or not enough information.
What is a No Match?
No Match means that the individual’s details do not match with Sanction watchlists.
How to determine whether a possible match is true or false
When an individual is flagged as a possible Sanction match, the next step is for your team to further investigate to determine whether the match is true or false.
Locating the Comply Advantage Report
To locate the information generated by Comply Advantage, follow the below steps:
- Navigate to the relevant case within the First AML Platform
- Click on the name of the relevant individual (with an orange or red flag)
- Click on the “Verifications” tab
- Scroll down to “Screening”
- Click the red “Match” text within the screening table
This will prompt a new tab to open containing all potential matches for the individual and the reasons for the match.
Selecting More Details for a potential match will display the sources of their match and any additional information.
Reviewing the Match
To review the match you will need to open the comply advantage report and determine which details match those of your clients. For example:
1. Name: Does their first, middle, and last name, match? Is the spelling the same? Is this a common name?
2. DOB: Does their date of the birth match?
3. Associated Country/Citizenship: Does their country/citizenship match?
4. Photo: If there is an image of the PEP, does it match your client?
If you cannot determine whether the match is true or false from these details, additional google searching of the individual is recommended, and you may choose to address this directly with your customer to assist.
Determining the next step
For individuals who have been flagged by First AML as a positive Sanction match or a possible Sanction match which is then determined by you to be a positive match, you will need to decide on the next step in accordance with your Compliance Programme and guidance from the regulators.
Please note that if a positive Sanction match is identified you may be required to terminate your relationship with the client and submit a report to regulators. To understand your obligations, view your regulator’s website or contact them directly for guidance.
Possible Match - False
For individuals who have been flagged as a possible match and determined by you to be a negative match, make a note of this within the Compliance Notes section of the case. Please note that the flag cannot be removed or changed.