During the screening process for the TFS, there might be a potential match to a name on the sanction list, a confirmed match, or a false positive.  

A potential match refers to a match between data in the Sanctions Lists with any name in the databases. However, it does not mean that the potential match is always subjected to Targeted Financial Sanctions. 

A confirmed match is when a potential match has been confirmed to be the individual, group, or entity subject to TFS. Also, if there is suspicion that the potential match may match an individual, group, or entity subject to TFS, it is considered a confirmed match. The company has to immediately freeze the funds and share the information with the FIU via goAML Portal in such a case. The company must notify within five days from freezing the funds or attempts to do so. 

If there is no matching result found in the sanctions list, then the company is free to conduct business as usual. Similarly, companies can enter into a business relationship with clients who were false positives. 

19. Do your AML/CFT systems in relation to suspicious transaction/ activity reporting include clear policies and procedures for post-reporting risk mitigation and prevention of tipping-off? 

Ans: Say ‘Yes’ if your AML/CFT systems in relation to suspicious transaction/ activity reporting include clear policies and procedures for post-reporting risk mitigation and prevention of tipping-off. 

20. Do you have measures in place to check, on an ongoing basis, that your AML/CFT systems in relation to suspicious transaction/ activity reporting comply with relevant legal and regulatory requirements and operate effectively? 

Ans: Say ‘Yes’ if you have measures in place to check, on an ongoing basis the AML/CFT systems in relation to suspicious transaction/ activity reporting comply with relevant legal and regulatory requirements and are operating effectively. 

21. Do you define a well-articulated workflow/ decision tree to decide whether or not a suspicious transaction/activities report should be filed? 

Ans: Say ‘Yes’ if you define a well-articulated workflow/ decision tree to decide whether or not a suspicious transaction/activities report should be filed.  

22. Do you have a process in place for the expedited filing of urgent suspicious transaction/activities reports in appropriate cases? 

Ans: Say ‘Yes’ if you have a process in place for the expedited filing of urgent suspicious transaction/activities reports in appropriate cases. 

23. Does the Compliance Officer or MLRO, or Deputy MRLO file a suspicious transaction/activities report to the FIU within 24 hours of the determination? 

Ans: Say ‘Yes’ if the Compliance Officer or MLRO, or Deputy MRLO file a suspicious transaction/activities report to the FIU within 24 hours of the determination. 

24. Are all decisions to file/ not to file suspicious transaction/activities reports documented and signed off by the MLRO or Head of Compliance or their deputy? 

Ans: Say ‘Yes’ if all decisions to file/ not to file suspicious transaction/activities reports are documented and signed off by the MLRO or Head of Compliance or their deputy. 

25. Do you maintain a register of all suspicious transaction/activities reports made to the FIU, as well as of all reports made by employees to the MLRO, including those where a decision is made by the MLRO not to report to the FIU? 

Ans: Say ‘Yes’ if you maintain a register of all suspicious transaction/activities reports made to the FIU, as well as of all reports made by employees to the MLRO, including those where a decision is made by the MLRO not to report to the FIU. 

26. Does your record of all ML/TF reports made to the MLRO include the following details a. Sufficient details of the customer concerned? 

Ans: Say ‘Yes’ if the record of all ML/TF reports made to the MLRO includes sufficient details with respect to the customer concerned.  

27. Does your record of all ML/TF reports made to the MLRO include the following details: The information giving rise to the suspicion? 

Ans: Say ‘Yes’ if the record of all ML/TF reports made to the MLRO includes the details of information giving rise to the suspicion. 

28. Does your record of all ML/TF reports made to the MLRO include the following details The date on which the report was made? 

Ans: Say ‘Yes’ if the record of all ML/TF reports made to the MLRO includes the date on which the report was made.  

29. Does your record of all ML/TF reports made to the MLRO include the following details are the staff members subsequently handling the report? 

Ans: Say ‘Yes’ if the record of all ML/TF reports made to the MLRO includes the details of the staff members subsequently handling the report. 

30. Does your record of all ML/TF reports made to the MLRO include the following details the result of the assessment? 

Ans: Say ‘Yes’ if the record of all ML/TF reports made to the MLRO includes the details pertaining to the result of the assessment. 

31. Does your record of all ML/TF reports made to the MLRO include the following details: a. whether the internal report result in a suspicious transaction/activities report to the FIU? 

Ans: Say ‘Yes’ if you comply with the requirements. 

32. Do you maintain a customer exit policy that outlines the process for reviewing the overall customer relationship and deciding on the next steps, including ending the relationship and notifying law enforcement and/or other group affiliates, as appropriate? 

Ans: Say ‘Yes’ if you maintain a customer exit policy that outlines the process for reviewing the overall customer relationship and deciding on the next steps, including ending the relationship and notifying law enforcement and/or other group affiliates, as appropriate. 

33. Do you provide sufficient training to your staff to enable them to form suspicion or to recognise the signs when ML/TF is taking place? 

Ans: Say ‘Yes’ if you provide sufficient training to your staff to enable them to form suspicion or to recognise the signs when ML/TF is taking place. 

34. Do you provide guidance to staff on identifying suspicious activity, taking into account the nature of the transactions and customer instructions that staff are likely to encounter? 

Ans: Say ‘Yes’ if you provide guidance to staff on identifying suspicious activity, taking into account the nature of the transactions and customer instructions that staff are likely to encounter. 

35. Do you provide guidance to staff on identifying suspicious activity taking into account the type of product or service? 

Ans: Say ‘Yes’ if you provide guidance to staff on identifying suspicious activity, taking into account the type of product or service. 

36. Do you provide guidance to staff on identifying suspicious activity taking into account the means of delivery, the customer risks, geographical risk and any risk derived from the change of circumstances? 

Ans: Say ‘Yes’ if you provide guidance to staff on identifying suspicious activity, taking into account the means of delivery, the customer risks, geographical risk and any risk derived from the change of circumstances. 

37. Do your STR/SAR documented procedures include red flags and suspicious indicators? 

Ans: Say ‘Yes’ if your STR/SAR documented procedures include red flags and suspicious indicators. 

38. Do you ensure staff are aware of and alert to the below situations/scenarios and consider them in certain circumstances to possibly give rise to suspicion? “Transactions or instructions which have no apparent legitimate purpose and/or appear not to have a commercial rationale” 

Ans: Say ‘Yes’ if you ensure that the staff are aware of and alert to the situations/scenarios which might possibly give rise to a suspicion that the Transactions or instructions have no apparent legitimate purpose and/or appear not to have a commercial rationale 

39. Do you ensure staff are aware of and alert to the below situations/scenarios and consider them in certain circumstances to possibly give rise to suspicion? “Transactions, instructions or activity that involve apparently unnecessary complexity or which do not constitute the most logical, convenient or secure way to do business” 

Ans: Say ‘Yes’ if you ensure that the staff are aware of and alert to the situations/scenarios which might possibly give rise to a suspicion that the transactions, instructions or activities that involve apparently unnecessary complexity or which do not constitute the most logical, convenient or secure way to do business 

40. Do you ensure staff are aware of and alert to the below situations/scenarios and consider them in certain circumstances to possibly give rise to suspicion? “where the transaction being requested by the customer, without reasonable explanation, is out of the ordinary range of services normally requested, or is outside the experience of the financial services business and DNFBPs in relation to the particular customer.” 

Ans: Say ‘Yes’ if you ensure that the staff are aware of and alert to the situations/scenarios which might possibly give rise to a suspicion that the transaction being requested by the customer, without reasonable explanation, is out of the ordinary range of services normally requested, or is outside the experience of the financial services business and DNFBPs in relation to the particular customer 

1. Do you freeze or suspend, without delay (within 24 hours), all funds or other assets upon identification of confirmed or potential match and refrain from providing any services?  

Ans: Say ‘Yes’ if you comply with the above requirements. 

2. Do you lift freezing measures, without delay (within 24 hours), on all funds or other assets upon receiving notice of de-listing of the designated person from EO Notification System or upon receiving communication from EOCN on goAML?  

Ans: Say ‘Yes’ if you comply with the above requirements. 

3. Do you implement Enhanced Due-Diligence (EDD) procedures on all Financial Transactions, including trade transactions linked to High-Risk Jurisdictions?  

Ans: Say ‘Yes’ if you comply with the above requirements.  

4. Do you have internal procedures to ensure that customers have a valid permit when dealing in the export and import of dual-use items before processing transactions or engaging in business relations?  

Ans: Say ‘Yes’ if you deal in dual-use items and comply with the requirements. 

5. Do you have alert systems that include both TF and PF sanctions evasion red flags?  

Ans: Say ‘Yes’ if you have an alert system for TF and PF sanction evasion red flags.