CAMS · Question #104
To ensure compliance with economic sanctions established by governmental authorities in the jurisdictions where it operates, a financial institution requires that all new and existing customers be…
The correct answer is A. No, screening should occur promptly after list updates. Screening customers at onboarding and quarterly thereafter is not sufficient to ensure compliance with economic sanctions, as sanctions lists may change frequently and the financial institution may not be aware of the latest updates. Screening should occur promptly after list…
Question
To ensure compliance with economic sanctions established by governmental authorities in the jurisdictions where it operates, a financial institution requires that all new and existing customers be screened at onboarding and quarterly thereafter. Is this step sufficient to ensure compliance?
Options
- ANo, screening should occur promptly after list updates
- BYes, this is recommended by the international guidance
- CNo, it is necessary to screen and perform enhanced due diligence on new relationships
- DYes, screening all existing customer relationships ensures the institutions is not dealing with a
How the community answered
(31 responses)- A81% (25)
- B10% (3)
- C6% (2)
- D3% (1)
Explanation
Screening customers at onboarding and quarterly thereafter is not sufficient to ensure compliance with economic sanctions, as sanctions lists may change frequently and the financial institution may not be aware of the latest updates. Screening should occur promptly after list updates to ensure that the financial institution is not dealing with a sanctioned individual or entity, or facilitating a prohibited transaction. This is recommended by the international guidance from the Financial Action Task Force (FATF) and the Wolfsberg Group. Screening and performing enhanced due diligence on new relationships is also important, but not the only step to ensure
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