1 Purpose and scope
This policy prevents funds or economic resources being made available, directly or indirectly, to persons and entities subject to applicable sanctions. It covers donors, partners, suppliers, beneficiaries and relevant controlling parties. Screening scope follows the relationship and legislation.(1)
2 Screening sources
The compliance lead uses official local and UN Security Council lists and updates, with alerts and re-screening of existing parties when lists change. A static saved list or general search engine is insufficient. List source, screening time, version and checker are recorded.
3 Verification timing
Screening occurs before accepting a relationship, disbursing or transferring funds, and when data or lists change. Available names and aliases, identity identifiers, birth date, nationality, entity information, addresses, ownership and control are reviewed. Spelling differences alone do not exclude a match; a similar name alone does not confirm one.
4 Potential and confirmed matches
A potential match suspends the transaction and is referred to the lead for verification using identifiers, evidence and competent guidance. Final classification requires documented reasons. Once listing applicability is confirmed, freezing requirements are implemented without delay or prior notice, preventing disposal, availability or transfer.
Funds must not be returned to the sender, moved to another account or reduced by fees on internal initiative. Amount, account, asset, time and action are documented; the bank and competent body are notified through mandatory reporting routes, instructions and deadlines. The policy gives the Board no power to override a freeze.
5 Reporting and lifting restrictions
Required reports and forms are submitted through the official channel applicable to the Association, with reference numbers and requests tracked. Unfreezing, exceptional payments or basic expenses require the authorised body’s permission and compliance with its conditions. Delisting or mistaken-identity resolution follows the appropriate official basis.
6 Oversight and continuity
A substitute is appointed and coverage and response tested without real individuals’ data in training. Screening outages are reported; transactions that cannot be screened stop until a reliable alternative is active. False, potential and confirmed match decisions and notices are retained confidentially and independently reviewed.
References in the approved document
- Cabinet Resolution No. 74 of 2020 on terrorism lists and implementation of UN Security Council resolutions; updated official lists and guidance of the Executive Office for Control and Non-Proliferation. This document establishes internal implementation controls without changing higher legal powers or requirements.