CS Professional · IFSCA - Regulations, Listing and Compliances · Book-keeping, Accounting, Taxation and Financial Crime Compliance Services and TAS
Kaveri Advisory, an IFSC unit, provides sanctions screening to a bank unit. A client name returns a possible match against a sanctions list, but the date of birth and nationality differ from the listed person. What is the correct compliance approach?
The alert should be escalated for review, the identifiers compared, and the reasoned decision documented before clearing or blocking. Clearing without records, rejecting every similar name or deleting the alert would not meet sound sanctions screening and audit expectations.
- ATreat it as a false positive and clear it without any documentation
- BReject all customers with similar names automatically
- CEscalate for review, compare identifiers, and record the reasoned decision before clearing or blockingCorrect
- DDelete the alert to avoid audit queries
Explanation
A potential match must be investigated using additional identifiers, and the outcome documented so it can be audited. Clearing without record, blanket rejection or deleting alerts all fail sound screening practice.
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