Chapter Five: Handling and Escalation of Alerts

In cases where a false name match occurs repeatedly, and after verifying that the match is false and inaccurate, the Financial Institution may consider adding the name to an "internal whitelist", and flagging the names included in those lists to be excluded from future alerts if supported by justification, provided that such list is subject to periodic review and approval by the Board of Directors or senior management, as the case may be, to ensure accuracy and compliance with the obligations set forth in the rules. This list shall also be subject to comprehensive screening, post update screening, and additional screening based on specific events as set out in Paragraph ( 3.6 ). 5.9 After taking the necessary freezing measures, the Financial Institution shall notify SAMA by email ( [email protected] ). The notification shall include sufficient information about the customer and the transaction, details of the freezing measures, the nature and value of the frozen funds, relevant listing information (United Nations list or national list), any transactions that have been carried out or attempted, and any relevant information or measures. Any additional information requested in this regard shall be provided within the time and through the mechanism specified by SAMA. 5.10 The Financial Institution shall verify that there are no instances of circumvention or evasion of Targeted Financial Sanctions by conducting the necessary reviews of ownership structures, transaction patterns, intermediaries, complex arrangements, and other. If there are indications of an attempt to evade or circumvent sanctions, or any suspicious financial behavior, a suspicious activity report (SAR) shall be submitted to the General Directorate of Financial Investigations in accordance with the regulatory requirements specified in the relevant regulations and instructions. 5.11 The Financial Institution shall provide adequate human and technical resources to the administrative unit responsible for processing and reviewing alerts and monitoring cases of circumvention or evasion of Targeted Financial Sanctions, taking into account the nature of its activities, the volume of its operations, and its level of risk exposure. It shall document and review the adequacy of human and technical resources on an annual basis. The review shall include findings and proposed recommendations. 5.12 The Financial Institution shall submit periodic reports to the Board of Directors or senior management, as the case may be, including the number of alerts by classification, the number of alerts closed by classification, the number of open alerts by classification, freezing measures, and timetables for updating Sanctions Lists.