DESIGNATION OF SANCTION LISTS
The FIU can publish designations pursuant to article 2, paragraph 1, section b of the Regulation Indicators Unusual Transactions. These designations pertain to the European Union (EU) and United Nations Security Council (UNSCR) sanction lists as well as sanction lists that have been imposed by the EU or the UNSCR and were subsequently implemented through national sanction decrees.
The head of FIU has decided to publish the following sanction lists:
- Designation Interim-Sanction Decree (Aanwijzing Interim landsbesluit prioritaire sanctieregimes AB 2019 no 47.)
- Designation Sanction decree chemical weapons (Aanwijzing Sanctiebesluit chemische wapens AB 2021 no. 31)
- Designation Sanction decree human rights violations (Aanwijzing Sanctiebesluit mensenrechtenschendingen AB 2021 no. 30)
- Designation Sanction decree Iran (Aanwijzing Sanctiebesluit Iran AB 2021 no. 141)
- Designation EU Sanctions freezing measures (Aanwijzing EU Sancties bevriezingsmaatregelen)
When there is a match with a (legal) person, entity or group listed in one of the sanction lists, this should be reported (promptly) to the FIU as an unusual transaction under indicator 130102. A mere ‘link’ with, for instance, a high-risk jurisdiction (e.g. North Korea, Iran etc.) is not sufficient to report an unusual transaction under the indicator referred to above. There must be an actual match with a designated (legal) person, entity or group listed on an UNSCR or EU sanction list. If there is no match but the transaction is deemed unusual it should be reported under one of the other indicators.
Available tools for sanction list screenings
The EU Sanctions Map provides an overview of the countries that are subject to EU sanctions as well as the measures that are implemented (e.g. freezing measures, travel restrictions, weapons embargo). This website merely serves as a tool and reference material for service providers but no rights or obligations can be derived from it. Service providers should consult EUR-Lex for the authentic acts and preambles to the EU sanction lists.
The FIU website also provides the link to the consolidated EU sanction lists, which can be used by service providers when screening EU sanction lists.
