Question 36
When exposure to a sanctioned party is identified and asset freezing is required, what action should a Sanctions Compliance Officer take?
- Inform the regulator and file a Suspicious Activity Report (SAR).
- Freeze the sanctioned party’s assets and inform the regulator as required by law.
- Freeze the sanctioned party’s assets and inform the party of its sanctioned status.
- Continue processing transactions for the sanctioned party as normal so as not to “tip off”.
Question 37
Primary sources of information used in sanctions investigations:
- provide direct evidence about a sanction or sanctions target.
- include the web, as Google searches are used to confirm the information contained in key legal documents.
- include key legal information documents, such as certified legal documentation and corporate registry searches.
- typically contain the same information as secondary sources.
Question 38
A risk-based approach to sanctions compliance, likely acceptable to auditors and regulators, could enable a firm to:
- not perform sanctions screening for any purely domestic business.
- not screen for cargo vessel names in domestic payments between domestic counterparties.
- screen solely against the sanctions lists published on regulator websites.
- not perform sanctions screening for clients, or their transactions, referred by the CEO or members of the board.