This Sanctions Policy is an FCA-aligned guide for ensuring compliance with UK, EU, and UN sanctions regimes under SAMLA 2018. Built on SYSC 6.3, OFSI guidance, and 2025 updates, it mitigates legal and reputational risks through proactive sanctions management.
It details risk assessments, screening processes, and reporting protocols, along with customisable templates such as alert logs and audit trails. Supporting SMCR accountability, FCA audits, and continuous improvement, it ensures robust compliance and operational integrity.
Includes:
Senior Management Responsibilities
Management Information (MI) and Reporting
Global and Group-Level Coordination
Conducting Sanctions Risk Assessments
Identifying High-Risk Factors
Mitigation Strategies and Controls
Horizon Scanning and Scenario Planning
Screening Tool Selection and Calibration
Data Sources and List Management
Ongoing Monitoring and Alert Handling
Testing and Tuning of Screening Systems
Customer Due Diligence (CDD) and Know Your Customer (KYC)
Beneficial Ownership and Control Checks
Enhanced Due Diligence (EDD) for High-Risk Clients
Training and Awareness
Alert Escalation and Investigation
Breach Reporting to OFSI and FCA
Asset Freezing and Management
Post-Incident Remediation
Third-Party Relationships
System Implementation and Integration
Record-Keeping and Documentation
Continuous Improvement and Adaptation
This Sanctions Policy is an FCA-aligned guide for ensuring compliance with UK, EU, and UN sanctions regimes under SAMLA 2018. Built on SYSC 6.3, OFSI guidance, and 2025 updates, it mitigates legal and reputational risks through proactive sanctions management.
It details risk assessments, screening processes, and reporting protocols, along with customisable templates such as alert logs and audit trails. Supporting SMCR accountability, FCA audits, and continuous improvement, it ensures robust compliance and operational integrity.
Includes:
Senior Management Responsibilities
Management Information (MI) and Reporting
Global and Group-Level Coordination
Conducting Sanctions Risk Assessments
Identifying High-Risk Factors
Mitigation Strategies and Controls
Horizon Scanning and Scenario Planning
Screening Tool Selection and Calibration
Data Sources and List Management
Ongoing Monitoring and Alert Handling
Testing and Tuning of Screening Systems
Customer Due Diligence (CDD) and Know Your Customer (KYC)
Beneficial Ownership and Control Checks
Enhanced Due Diligence (EDD) for High-Risk Clients
Training and Awareness
Alert Escalation and Investigation
Breach Reporting to OFSI and FCA
Asset Freezing and Management
Post-Incident Remediation
Third-Party Relationships
System Implementation and Integration
Record-Keeping and Documentation
Continuous Improvement and Adaptation
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