A possible sanctions match does not automatically mean that your client is a designated person. It simply means that the client's details closely match an individual or entity on the UK Financial Sanctions List and require further review.
You should download the report and review the information returned. The report contains the details of the potential match, allowing you to compare it with the identity information you hold for your client.
You should carefully compare the information returned in the report with the identity information you hold for your client, including their name, date of birth, nationality, address, and any other identifying details.
You may find that your client's name matches one or more entries on the sanctions list. However, this does not necessarily mean that your client is the same individual or entity.
Do not ask your client whether they are subject to sanctions or disclose that a potential sanctions match has been identified. Doing so could constitute tipping off, which is a criminal offence in certain circumstances.
If you are satisfied that your client is not the individual or entity identified on the sanctions list, you can select "Manually Verified – No Match" from the Action Required drop-down menu. You should record the rationale for your decision as a compliance note on the transaction.
If all the details match the information on the sanctions list, this is likely to be a target match. In this case, you should select "Manually Verified – Sanctions" from the Action Required drop-down menu.
Where there is a confirmed sanctions match, you should:
- Suspend the transaction immediately.
- Notify your Money Laundering Officer (MLO). If an MLO has been assigned within Movebutler, the system will automatically send them an email notification.
- Report the matter to the Office of Financial Sanctions Implementation (OFSI) in accordance with your legal obligations.
Estate agents are legally required to report sanctions-related information to OFSI. Failure to do so may constitute a criminal offence and could result in prosecution or a monetary penalty.
If, after reviewing the available information, you are still unsure whether you have identified a genuine sanctions match, you should contact OFSI for guidance before proceeding.
You should also consider whether the circumstances give rise to a suspicion of money laundering or terrorist financing, in which case a report to the National Crime Agency (NCA) may also be required.