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JFSC Sanctions screening systems thematic feedback published.



In the first quarter of 2022, the JFSC asked 65 supervised persons to complete a thematic questionnaire in relation to targeted financial sanctions.

The questionnaire sought to gather information concerning:

  1. How those businesses implemented targeted financial sanctions
  2. How impacted customers, transactions and activity were identified.
  3. The type and nature of screening undertaken.
  4. Tools used.
  5. Systems and controls (including policies and procedures) established to identify and report instances where there may be a connection to a designated person or entity.


Additionally, during the fourth quarter of 2022, the JFSC undertook a thematic examination to assess sanctions screening systems used by 23 supervised persons.

The aim of the examination was to test client and transaction screening tools used by supervised persons to understand their:

  1. Effectiveness: the ability to create a match against the name of a designated person.
  2. Efficiency: the number of alerts generated by the screening tool per name screened.


The JFSC feedback paper provides details in relation to the questionnaire responses, findings from the thematic examination and relevant examples of good practice:


The JFS says

  • All supervised persons should review this feedback and consider whether enhancements to their systems and controls are required.

Guidance to assist supervised persons in meeting their legal obligations under sanctions legislation can be found on the JFSC website.


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