Frequently Asked Questions
- What is the difference between a name match and a target match?
- What are the reporting requirements for name or target matches?
- How often do I need to scan my customer database for possible target matches?
- Should an institution always contact the Bank if we have found a name match or a possible target match?
A target match is where you are satisfied that the account held is that of the target of the financial sanctions. A name match is where you have matched the name of an account holder with the name of a target included on the Bank’s consolidated list. This does not necessarily mean that the account holder is one and the same as the target.
All financial institutions and other bodies and persons in the UK are required to inform the Bank of all funds that they have frozen in accordance with the relevant legislation and provide all relevant information necessary for ensuring compliance with the legislation. Under existing UK financial sanctions legislation, an institution is guilty of an offence if it knows or suspects that a person who is, or has been at any time since the coming into force of the relevant legislation, a customer of the institution, or is a person with whom the institution has had dealings in the course of its business since that time (a) is a listed person, (b) is a person acting on behalf of a listed person, or (c) has committed an offence under the legislation, and it does not disclose the information on which the knowledge or suspicion is based to HM Treasury (via the Bank) as soon as is reasonably practicable after that information comes to its attention.
Your internal policy and procedures should determine the frequency of scanning. It is each individuals or institutions responsibility to comply with the relevant legislation. However, if you fail to identify and block a target account, this may lead to a breach of the legislation. It should be noted that a critical aspect of the listing of a target is that the target’s assets must be frozen immediately, before they can be removed from UK jurisdiction.
Positive target matches should always be reported to the Bank. In the event that you identify an account as that of a target of financial sanctions then the account must be frozen and details reported to the Financial Sanctions Unit.
However, name matches are not necessarily target matches. The more likely scenario is that you may identify a name match with one of the persons included on the Bank’s consolidated list. In such cases, you should initially conduct your own enquiries assessing your Know Your Customer information and customer profile against the details available on the consolidated list. If, after assessing all available information, you are unable to determine whether a customer is indeed one and the same as a listed person/entity and wish to seek guidance from the Bank then you should contact the Financial Sanctions Unit either by post or by e-mail at email@example.com. Any relevant information held in respect of the customer would be required i.e. full name, date and place of birth, occupation, address, family details etc. It should be noted that as EC Regulations are directly applicable in Community Law, any opinion given by the Bank of England in respect of a target covered by an EC Regulation has no legal force.