2.1. Senior Management Commitment

يسري تنفيذه من تاريخ 4/7/2021

Senior management is defined broadly to include senior leadership, executives, and the board of directors. Senior management’s commitment to, and support of, the LFI’s SCP is one of the most important factors in determining its success. In order to facilitate effective senior management commitment, an LFI should:

	•	Ensure that senior management has reviewed and approved the organization’s SCP.
	•	Ensure that senior management has reviewed and approved the methodology used for undertaking the risk assessment and reviewed and approved the LFI’s risk assessments at least on an annual basis.
	•	Clearly designate the personnel responsible for ensuring proper implementation of the SCP, including day-to-day operations, and compliance with statutory obligations. This personnel should have the appropriate competencies and experience, or be appropriately trained, to perform the duties and responsibilities associated with this role, has sufficient seniority, and is delegated sufficient authority and autonomy in order to discharge the LFI’s responsibilities. The personnel may have other responsibilities in the LFI, provided that these responsibilities do not conflict with their role in implementing the SCP. For example, large LFIs may choose to hire a dedicated sanctions compliance officer, while smaller LFIs may choose a specific officer or manager currently working at the LFI to be responsible for the SCP in addition to their other duties.
	•	Ensure the existence of direct reporting lines between the personnel responsible for the SCP and senior management to facilitate the escalation of financial sanctions issues, including regular and periodic meetings.
	•	Ensure that the SCP is fully integrated into the organization’s daily operations and allocated adequate resources in the form of human capital, expertise, information technology, and other resources as appropriate.
	•	Recognize compliance failings and implement necessary measures to reduce future incidents, including through addressing root causes and implementing systemic solutions.