In recent weeks, the burden on financial institutions to ensure full compliance with the sanctions protocols across territorial boundaries has increased by an order of magnitude. Sanctions screening compliance is a key concern for investment managers and regulators and a breach could have severe legal, financial and reputational consequences.
In light of the sanctions imposed by several countries and multilateral organisations on the Russian Federation and Belarus, AIMA, together with the support of its sponsoring partners Dechert and SS&C, and a group of dedicated member volunteers, have developed this Guide to provide members with guidance that can be used as a starting point for how they should consider managing sanctions risk. The guidance covers, among others, topics such as sanctions screening, risk assessment, policies and procedures, roles and responsibilities, and the screening process.
Please note that the Guide to Sound Practices for Sanctions Screening, as with all AIMA GSPs, is jurisdiction neutral. It may also be subject to change in the coming months to take into consideration any further developments and sound practices that may arise as a result of current events.
In addition, AIMA has also created a separate webpage on sanctions as an additional resource where members can find an overview of the most recent advisories published by regulatory authorities that firms should consider.
Table of contents
2 Sanctions screening
3 Types of sanction screening
4 Risk assessment
5 Policies and procedures
6 Roles and responsibilities
7 The screening process
7.1 Quality of information
7.2 'Fuzzy' searching
7.3 False positives and false negatives
7.4 Screening tools
8 Frequency of sanctions screening
9 Dealing with positive identification
10 Testing, monitoring and training