The following were all common misconceptions discovered by the Financial Services Authority when carrying out one of their thematic reviews.
We are exempt because we only deal with mortgages, small insurance plans and low premiums.
This is not money laundering legislation and there are no small premium exemptions in fact there are no exemptions at all. Any transaction, however small, results in the need to ensure your client is not on the list.
NB The requirements apply even if no product is sold. Provision of any advice, goods or service requires you to have first screened the client against the list.
All the people and organisations on the list are all based overseas.
At the time of writing there are currently 50 individuals and 12 organisations on the list that are resident or based in the United Kingdom.
It is fair to say that in all likelihood, your client will not be one of them - but the fact is you have to be able to prove this. How could you without SanctionsSearch.com?
We don’t need to screen our clients as we don’t hold client money and we do not take or make payments. We deal with the type of products that would not be used for financial crime.
Remember! You need to screen clients even for the advice you provide regardless of the absence of any product sale. Almost all products and services, however small, can be in some way used in financial crime - so no one is exempt.
We only provide insurance. That type of product is little or no risk for financial sanctions. We don’t believe financial sanctions apply to insurance.
The Terrorism Order prohibits the provision of goods or services, including insurance, to a target on the HM Treasury list.
To reiterate, it is not only the product but also the act of providing advice which means you must ensure your customer is not on the sanctions list.