FICA and Russian Sanctions

By now it is old news that many of Russia's Politically Exposed Persons, entities and Prominent Influential Persons have been sanctioned. In terms of FICA, you may not deal with any sanctioned person and this may also be a reportable activity if any financial transactions are attempted.

This is just a reminder that all FSP's must check if their clients are sanctioned at onboarding stage (and keep proof of this) and whenever you are updating FICA information in line with the client risk rating being low medium or high.

If you are not using AML software to onboard clients you can search for sanctioned persons and entities on the following websites. The links work as a time of publishing this blog post.

The OFAC sanctions list is most up to date and works best:
https://sanctionssearch.ofac.treas.gov/

The FIC search function exists but in my opinion is not 100% reliable and has some bug (for instance, it does not return results if all information is not entered):
https://www.fic.gov.za/International/sanctions/SitePages/Home.aspx