Rules for the Implementation of Targeted Financial Sanctions

The financial institution shall update its internal lists immediately upon the issuance of an announcement or notification regarding the listing of any person or group of persons in the sanctions lists, and shall monitor and update its internal lists on a daily basis through official websites and channels, and shall maintain a record documenting the time of receipt of updates, their application, and their confirmation in internal systems. 4.2 Without prejudice to the provisions of Chapter Three of the screening procedures and controls regarding reliance on automated or manual screening tools and systems, financial institutions shall take into account that reliance on such tools may not be deemed a guarantee of compliance with the instructions set out in the rules. Rather, daily and continuous verification operations shall be carried out, and internal lists shall be updated from the official websites and channels of the sanctions committees and the Permanent Counter Terrorism Committee (PCTC), under the Presidency of State Security, and the Standing Committee for the Implementation of Security Council Resolutions issued in accordance with Chapter Seven at the Ministry of Foreign Affairs, and the website and channels of the United Nations sanctions committees. 4.3 The financial institution shall consolidate all updated sanctions lists into an approved internal list, which shall be regularly updated based on the updates received from the competent authorities as stated in paragraphs (4.1) and (4.2). This list shall include the names of persons listed in the sanctions lists, the financial institution may add to the consolidated list the names of persons listed in lists issued and made available by other countries. Chapter Five: Handling and Escalation of Alerts 5.1 The Financial Institution shall rely on an organized and time-bound mechanism to review and process alerts issued by screening systems and tools. This mechanism shall include clear procedures for assessing and classifying the severity of the alert, escalation procedures, and the immediate, rapid, accurate, and documented determination of potential matches to establish whether the match is true or false. The Financial Institution shall periodically and continuously review the effectiveness and appropriateness of this mechanism. 5.2 The Financial Institution shall regularly review all alerts generated by screening systems and tools, prioritizing high-risk alerts and ensuring low-risk alerts are reviewed within a reasonable and appropriate timeframe, as determined in accordance with the Financial Institution's risk appetite. 5.3 The review and handling of alerts at the Financial Institution shall be conducted by two specialists (maker-and-checker) to ensure dual screening, who possess sufficient experience and knowledge in Targeted Financial Sanctions, with the possibility of supporting the processing of alerts based on information obtained through the application of due diligence measures, external sources such as public records, or information and news available from open sources. 5.4 If there are sufficient reasons to confirm that the alert is merely a false match, the Financial Institution's specialists may close the alert after following the required internal procedures, while retaining a written justification explaining the reasons for closure and the invalidity of the alert. If the specialists are unable to close the alert for any reason, it shall be escalated directly to the senior manager with the appropriate expertise and authority to assess the match and take appropriate action in accordance with the instructions contained in the rules.