Sanctions Checking:
What is Sanctions Checking?
Sanction checking is a Government level check on a group or individuals. Restrictions are placed upon sanctioned individuals and those conducting business with them are heavily penalised.
Who manages Sanctions Checking in the UK?
In the UK, Her Majesty’s Treasury (HMT) is the competent authority for sanctions and ‘The Office of Financial Sanctions Implementation’ (OFSI) being the enforcer (since 2016). The Financial Conduct Authority (FCA) is responsible for ensuring that firms have adequate systems and controls to comply with U.K. sanctions requirements.
What should I do if someone is flagged for a Sanctions Check?
Sanctions checking isn't an exact science, and the match threshold is set at 70%. This means, if there is enough data on the customer record to be a 70% match with a record on the HMT list it will flag to Stroll that a sanctions review is needed.
Should I let the customer know these have been flagged for review?
Quick answer: No. As the matching process is not 100% accurate, we shouldn't let a customer know that they have been flagged as a potential match.
What should I do if someone is flagged as a potential match?
If a customer is flagged as a potential match you will be presented with an additional screen on OGI. This screen lets you see an overview of the customer's details, and the details of the HMT record that the customer has been paired to. You can review this information and complete one of the following actions:
- View more info: Pressing F8 or 'View' will allow you to view from information relating to the potential match to help make a judgement on whether the match is valid or invalid. You may need to ask the customer a few more details to help clarify, such as whether or not they are using a middle name instead of a forename.
- Override: If you are happy that the match is not valid, you should override the match. Press F2 or 'Override' and add a reason why you have made that decision.
- If it is not a match, enter: 'Not a match'
- Match: If you suspect that it is a match, click 'Exit'. This will mean that the warning will not be suppressed and it will be presented to the next agent who enters the record. You must then refer the case.
What if a customer is a match?
If you are confident that a customer is a match, advise that you need to make a referral to ensure that the policy can be placed on cover for them. Refer the case to your line manager who will liaise with Compliance to determine the next steps.
When are Sanction checks completed?
Sanction checks are completed at the point that a new quote is being transferred to Core to put a policy on cover.
Sanctions checks are completed for each MTA.
Sanctions checks are run in batches every 90 days to review all customer records.