Rules for the Implementation of Targeted Financial Sanctions

The screening systems and tools relied upon by the Financial Institution shall be capable of detecting any matches of names, aliases, variations in spelling, names with similar phonetic pronunciations, and transliterations, and the Financial Institution shall verify the effectiveness of these systems and tools on a periodic and ongoing basis. 3.8 The Financial Institution shall select screening systems and tools that are appropriate to the nature of its activities, the scale of its operations, and its level of exposure to risks, and shall rely on robust and highly reliable automated systems capable of real-time matching against sanctions lists, and shall periodically and continuously review the effectiveness of the real-time matching of those systems and address deficiencies based on the results of the assessment in accordance with paragraph (3.12). 3.9 The Financial Institution may, after obtaining written non-objection from SAMA, use robust and documented manual tools commensurate with the nature of its activities, the scale of its operations, and its level of exposure to risks, in accordance with the following requirements: a. ‌There shall be no delay in implementing the requirements for immediate screening against sanctions lists, freezing measures, reporting procedures, and unfreezing procedures. b. These procedures and tools shall support the regular updating of sanctions lists based on official sources. c. Accurate implementation of screening procedures by trained personnel. d. Assess partial or close matches using consistent and documented criteria. e. Fully documenting screening records and decisions and making them available for review upon request. f. The exception shall not apply to Financial Institution offer payment or transfer products or services. 3.10 The Financial Institution shall document in its procedures any matching methodology it uses in its screening systems and tools, including the matching logic, the matching mechanism, and the matching criteria, and shall ensure that the methodology is commensurate with the nature of its activities, the scale of its operations, and its level of exposure to risks, and shall periodically and continuously reviews its effectiveness and update it based on the results of the assessment in accordance with the requirements set out in paragraph (3.11). 3.11 The Financial Institution shall document and approve any amendments to its approved screening procedures and mechanisms, including the justifications for the amendments, and shall attach those amendments to the policies and procedures approved by the board of directors or senior management, as applicable, provided that their approval is preceded by the necessary tests to ensure the effectiveness of the amendments made and to ensure that they do not affect the Financial Institution's obligations set out in the rules and instructions related to Targeted Financial Sanctions. 3.12 The Financial Institution shall regularly test the effectiveness of the screening mechanisms to verify their compliance with the requirements set out in the rules and instructions related to Targeted Financial Sanctions, thereby ensuring the accuracy of match detection, reducing cases of incomplete matches, reviewing the filtering criteria used in searches, reviewing scenario-based verification processes, analyzing cases where matches are not detected despite the existence of actual matches, and not limiting the review to name matches only, but also including cases that may arise from indirect matching. These tests, their results, and the actions taken to address any deficiencies discovered shall be documented. Chapter Four: Sanctions Lists Management