CS Professional · IFSCA - Regulations, Listing and Compliances · Book-keeping, Accounting, Taxation and Financial Crime Compliance Services and TAS
Ledgerline, an IFSC unit, provides sanctions screening to a bank customer. A screening alert shows a possible name match with a sanctioned person, with differing dates of birth. What is the appropriate handling?
The alert should be investigated using further identifiers such as address and nationality, the decision documented, and the case escalated if a true match cannot be ruled out. Automatic clearing, blanket freezing or deleting the alert would be improper and would destroy the audit trail.
- AClear the alert automatically because the dates of birth differ
- BInvestigate the potential match using additional identifiers, document the decision and escalate if it cannot be ruled outCorrect
- CFreeze every account with a similar name without review
- DDelete the alert to avoid false positives in reports
Explanation
A potential match must be investigated with other identifiers and the outcome documented, with escalation if a true match cannot be excluded. Auto-clearing on one differing data point is unsafe, mass freezing is disproportionate, and deleting alerts destroys the audit trail.
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