Regulatory Alerts2024-06-04
Guidelines on Internal Policies, Controls and Procedures for the Implementation of Restrictive Measures (Article 15 of the Sanctions Act)
The Croatian Financial Services Supervisory Agency (Hanfa) issued guidelines requiring supervised entities to establish, implement, and regularly update internal policies, controls, and procedures for enforcing restrictive measures. The document mandates a robust governance framework where the management body oversees compliance, while a designated compliance officer conducts risk assessments, maintains effective screening processes, and reports to regulators. Entities must ensure these measures are proportionate to their risk exposure, supported by adequate resources, and reinforced through targeted employee training and regular audits.
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