Regulatory Alerts2019-08-29 | 29617Added · Updated
MOAGLA Guidance: Assessing Name Matches for TFS
The Ministry of the Attorney General and Legal Affairs issues guidance to Financial Institutions, Listed Businesses, Non-Profit Organizations, and the public on determining valid name matches against UN Security Council sanctions lists under the Anti-Terrorism Act and related Economic Sanctions Orders. The document mandates a four-step verification process for transactions and accounts, requiring entities to reject matches involving entity type mismatches or partial name overlaps, and to gather additional identifier information before proceeding. If a valid match is confirmed, entities must immediately halt the transaction or account operation and report the suspicion to the Financial Intelligence Unit via specific economic sanctions, terrorism financing, or suspicious activity reports. The guidance also clarifies that low-quality aliases should not be relied upon in isolation for screening decisions.
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