An excerpt of the amendment follows hereunder:
“Amongst others, these amendments empower the Sanctions Monitoring Board to mete out administrative penalties for any violation of Article 17(6) of the National Interest (Enabling Powers) Act which is applicable to any legal or natural person conducting a relevant activity or relevant financial business as defined in the Prevention of Money Laundering and Funding of Terrorism Regulations. The obligations as per article 17(6) are as follows:
1. To regularly check the list of UN, EU or national designations and to screen client databases against those lists on a regular basis and immediately after a change to any of those lists occurs.
2. To have in place and effectively implement internal controls and procedures to ensure compliance with the obligations arising from the Act and any relevant UN resolutions, EU regulations or national measures.
3. To notify the Board in case targeted property is identified and of the actions taken in relation to such property in compliance with the requirements under this Act.”
Fortunately, InScope can help subject persons comply with this amendment, as InScope automatically checks all client data against UN, EU and national designations. This allows Subject Persons to effectively implement the internal controls they have in place by screening all entities daily, enabling notification to the Board if a ‘hit’ is found. This process is undertaken every day to allow pertinent action.
If you would like further information on InScope or on how to access these Sanctions Checks if you are already a customer feel free to contact us!
