Regulatory Alerts2022-07-22
Supervisory Benchmark No 2/2018 as amended on 22 July 2022 on the requirements for selected procedures for the implementation of international sanctions
The Czech National Bank issued this amended supervisory benchmark to address repeated audit findings regarding the inadequate implementation of international sanctions by supervised institutions. It mandates that institutions establish detailed internal procedures to identify persons subject to financial sanctions, including clients, beneficial owners, and transaction counterparties, while ensuring timely reporting of matches to the Financial Analytical Office. The document further requires proactive, ongoing sanctions screening across all products and domestic payment systems, explicitly rejecting reliance on client declarations or third-party checks as sufficient compliance measures.
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