MLR3C10180 - Compliance with Financial Sanctions arising from UN and EU Resolutions and Regulations

The Financial Sanctions requirements originate from UN resolutions and/or EU regulations. These measures or sanctions place an embargo on financial transactions being entered into with or on the behalf of targeted individuals, entities and countries. The object of the sanctions is to prevent the movement of funds to support terrorism. Detailed guidance is in Appendix 8 of the Anti Money Laundering guide for Money Service Businesses.

The Financial Sanctions work in a similar way to the Directions under Schedule 7 Counter Terrorism Act. Responsibility for the sanctions rests with the Foreign & Commonwealth Office who oversee the policy with the responsibility for implementation and administration resting with HM Treasury. Notification of persons or entities that are subject to financial sanctions and asset freezes are published on the Treasury website.

When visiting a Money Service Business a compliance check should include the following.

• Is the business registered with HM Treasury to receive alerts relating to the imposition of sanctions? Businesses and Visiting Officers should register to receive the alerts by contacting http://www.hm-treasury.gov.uk/fin_sanctions_currentindex.htm

As part of its risk based approach has the business taken appropriate measures so that it is able to identify transactions that are subject to financial sanction? Are computerised and manual systems able to recognise transactions that are subject to financial sanction?

• Have staff employed in the business been trained in their responsibilities in relation to the imposition of sanctions.