Text for CQS CPMS Policy
CQS Policy: Financial Sanctions
Purchase this policy: Anti-Money Laundering Policy
- Change date
- 07/06/2023
- Word count
- 399
- Deployment measure
- 8/10
Rationale
The Government’s financial sanctions regime is continually changing. It is important that firms now update their policies to take into account the risks concerning financial sanctions. The sanctions regime is not the same as the Anti-Money Laundering regime and it is important for staff to know the difference. This paragraph guides them to the differences and location of the Sanctions Policy.
AML, counter-terrorist financing (CTF) and counter-proliferation financing systems are not enough to ensure compliance with the sanctions regime. A 25% beneficial ownership test applies with the AML regime whereas the ownership and control test for sanctions is very wide and
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