How do we onboard a customer with partial match results in the screening solution?
In case when the name screening of the customer suggests that some of the parameters of the customer screened match with the person sanctioned under UAE Local or UNSC Consolidated Sanctions List, and the regulated entity is unable to conclude whether the hits are confirmed match or false match on account of missing details, then it is obligatory for the regulated entity to suspend the customer onboarding and file a “Partial Name Match Report” (PNMR) on the goAML Portal. The regulated entity must provide the details of the customer screened and the possible hit results with which a partial match is identified in such PNMR. The authorities shall review and analyse the partial match details and share their feedback on whether it is actually a match or not. The regulated entity must not engage with such customers unless the partial match with UAE Local or UNSC Consolidated Sanctions lists are resolved.
If the screening tool shows a partial match with other sanctions lists or adverse media, the regulated entity must evaluate the case and decide to onboard, adopting a risk-based approach. The regulated entity may consider filing a Suspicious Activity Report with FIU if necessary. It is important to note that the decision to onboard such customers must be aligned with the regulated entity’s Customer Acceptance Policy and risk appetite.
Thank you for your valuable advice. Kindly let me know what the procedure will be to onboard the customer if the screening tool shows a partial match with other sanctions lists or adverse media. How to apply the risk-based approach?
When there is a partial match with other sanctions lists or adverse media, you will have to request additional information from the customer (without tipping-off), which may help you evaluate the possibility of a confirmed or false match.
The risk-based approach is all about what risk you foresee from that transaction or customer and whether you have controls to effectively manage the same within your risk appetite.
It is advisable to refrain from establishing a business relationship if your customers, suppliers, or associated parties have ties with a country that has imposed sanctions.
If it is related to adverse media, you will have to evaluate the nature of negative news (financial crime or other), how old the matter is, what is the current status of that matter (as in whether the person has been convicted or not), etc. Again, you will have to decide on these facts and other transactional elements like value, mode of payment, etc.
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