Rules for the Implementation of Targeted Financial Sanctions

The senior administrative official at the Financial Institution shall verify the alert and its direct or indirect connection to a listed person. If sufficient grounds to support this, the funds shall be frozen without delay, and the Financial Institution shall not delay the freezing measures pending approval by an internal committee, legal review, approval by senior management, or for any other reason, if the match is confirmed. 5.6 The Financial Institution shall document all actions taken in response to alerts, whether closing or escalating them, and maintain detailed records thereof, with the documentation including at least the following information and elements: a. The time and date the alert was received. b. The time and date of processing the alert, and the time and date of escalation, if any. c. The source of the alert (e.g., United Nations Security Council lists or national lists). d. The nature of the alert (e.g., a name match, an indirect match, or a match related to evasion or circumvention of Targeted Financial Sanctions). e. The action taken, with supporting justifications. f. Names of the specialists responsible for processing the alert. g. The outcome of the alert processing (e.g., false positive, confirmed match, or notification to SAMA). h. Data and information on any freezing operation that has been carried out. 5.7 The Financial Institution shall take adequate measures to ensure the confidentiality of alerts and their processing, and to prevent alerts and notifications from being disclosed to the customer, a third party, or any other relevant parties, internal or external, directly or indirectly, regarding the existence of a match related to the Sanctions Lists, the intention to freeze funds, or that a review is underway, except for reporting to SAMA in accordance with the provisions of paragraph (5.9) and the General Administration of Financial Investigations in accordance with the provisions of Paragraph (5.10). 5.8 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.