3.4. Name Screening

Effective from 4/7/2021

In addition to the regular screening utilizing the UN Consolidated List and Local Terrorist List indicated above, LFIs should maintain the following sanctions compliance procedures to prevent and detect sanctions breaches:

1.

Ownership/Control Rule: Individuals or legal entities that are directly or indirectly owned or controlled mainly or fully by one or more Listed Person are subject to the same prohibitions as the Listed Person, even if such individuals or legal entities are not specifically named by the competent authority on the respective UN Consolidated List or Local Terrorist List.

The criterion to be taken into account when assessing whether an individual or legal entity is mainly owned by a Listed Person is the possession of more than 50% of the proprietary rights of an entity or having majority interest in it. If this criterion is satisfied, it is considered that the individual or legal entity is owned by a Listed Person.

The criteria to be taken into account when assessing whether an individual or legal entity or arrangement is mainly controlled by a Listed Person, alone or pursuant to an agreement with another shareholder or other third party, include the following:

•	Having the right to appoint or remove a majority of the members of the administrative or management body of such a legal person, entity, group or arrangement;
•	Having appointed solely as a result of the exercise of one's voting rights a majority of the members of the administrative or management body of a legal person, entity, group or arrangement who have held office during the present and previous financial year;
•	Controlling alone, pursuant to an agreement with other shareholders in or members of a legal person, group or entity, a majority of shareholders' or members' voting rights in that legal person, entity, group or arrangement;
•	Having the right to exercise a dominant influence over a legal person, group or entity, pursuant to an agreement entered into with that legal person, entity, group or arrangement, or to a provision in its Memorandum or Articles of Association, where the law governing that legal person, entity, group or arrangement permits its being subject to such agreement or provision;
•	Having the power to exercise the right to exercise a dominant influence referred to in the previous point, without being the holder of that right;
•	Having the right to use all or part of the assets of that legal person, entity, group or arrangement;
•	Managing the business of that legal person, entity, group or arrangement on a unified basis, while publishing consolidated accounts; or
•	Sharing jointly and severally the financial liabilities of legal person, entity, group or arrangement, or guaranteeing them.
	2.	Fuzzy Matching: An algorithm-based technique to match one data point, where the contents of the information being screened is not identical, but its spelling, pattern or sound is a close match to the contents contained on a list used for screening.
	3.	Weak or Low-quality Aliases: Relatively broad or generic alias may generate a large volume of false hits when such names are run through a computer-based screening system. LFIs should perform their own assessments on whether to screen for weak aliases based on their understanding of their own risk profile.