Step-By-Step Guide to Sanction Screening

The Federal Decree-Law on AML and Cabinet Decision No. (10) of 2019 regarding the implementation of the Federal Decree Law and the Cabinet Decision No. 74 of 2020 require Financial Institutions (FIs), Designated Non-Financial Businesses Professions (DNFBPs), and Virtual Assets and Service Providers (VASPs) to have in place a Sanctions Screening procedure, usually forming a part of the sanctions compliance program. This infographic provides a step-by-step guide to sanction screening.

The sanction Screening process entails several steps, right from collecting key identifier information of the legal or natural person to be screened; the correct sequence of the name process is discussed as follows:

Step-by-step guide to name screening

1. Understand regulatory requirements

When, Why, What and How of screening requirements. It is essential to understand the timing of conducting sanctions screening, the reason for conducting sanctions screening and the process of conducting sanctions screening.

2. Finalise relevant sanction lists

UAE Local List and UNSC Consolidated List to meet TFS compliance requirements in UAE.

3. Choose a sanction screening software

The sanction screening software must comply with regulatory requirements and be efficient in handling false matches to reduce manual effort. Further, it must provide an audit trail to meet record-keeping requirements around TFS compliance.

4. Collect and screen customer information

At a minimum, collect the customer’s or prospective customer’s first name, middle name, last name, full name, or name in the original script. Further, collect the nationality, ID number, and gender-related information.

If the customer refuses to provide KYC information or appears suspicious, file an internal SAR or STR for the compliance officer to take a call if it requires filing SAR or STR with the FIU goAML portal.

5. Analyse matches

– Analyse positive matches. For a full match, first, prepare an internal FFR for further analysis by the compliance officer.

– If it’s a partial match, then submit an internal PNMR for further investigation by the compliance officer.

– If there’s a no match, then proceed towards performing the customer due diligence (CDD)

6. Regulatory Filing

The Compliance officer reviews the internal SAR/STR, PNMR, and FFR and considers their submission on the goAML portal. If he decides against the submission, then he must record the reasons behind it.

7. Ongoing monitoring

Perform ongoing monitoring of customers to identify any unusual patterns or transactions.