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2.3. Sanctions Risk Appetite

Effective from 4/7/2021

LFIs should develop and maintain a comprehensive written sanctions risk appetite approved by the LFI’s senior management and embedded through policies, procedures, and screening systems parameterization.

 The sanctions risk appetite should specify which sanctions regimes are applicable to the LFI (for example UNSCR, OFAC, EU, UK etc.).
 LFIs should specify their policy on treating of interests, properties, assets, or entities that are owned or controlled 50% or more by a Listed Person.
 LFIs should specify their approach on mitigating the risk of breaching of unilateral sanctions, especially in the context of sanctions that may have extra-territorial implications or the Listed Persons may or may not have a presence in UAE (for example secondary sanctions by OFAC).
 LFIs should specify their approach on screening of alias names such as one word synonyms, vessel names or paper based instruments.
 LFIs should identify and document any exceptions to sanctions risk appetite or deviations from their policies and procedures; these should be approved by senior management.
 

For more details and information, please refer to Annex 2 for related Lessons learned from CBUAE Supervision.