You should review all the client identity information you hold against the sanctions list provided, to make sure you do not have a false-positive identification.
You may also ask your client for more identity information to help confirm or rule out whether there's an accurate match. You must not disclose the potential sanction match to your client.
You may find that the name of an individual or entity you’re dealing with matches one or more entries on the list.
However, it does not necessarily mean that the individual or entity you're dealing with is the same one on the list.
If you’re satisfied that this is the case, you do not need to take further action and you can select "Manually Verified - No Match" from the action required box.
If the individual or entity you’re dealing with matches all the information on the list, this is likely to be a target match. If this was the case, you'd select "Manually Verified - Match" from the action required box.
Where there’s a positive match, you must suspend the transaction and report the matter to your Money Laundering Officer (MLO). The system will automatically send an email notification to them too.
Estate Agents have an obligation to report sanctions-related information to OFSI. Not doing so is a criminal offence, which may result in criminal prosecution or a monetary penalty.
If, having consulted the consolidated list, you’re still unsure on whether you have a target match, contact OFSI for assistance.
Email: ofsi@hmtreasury.gsi.gov.uk
General enquiries: 020 7270 5454
You should also consider whether you have a suspicion of money laundering or terrorist financing which requires a report to the National Crime Agency.
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