Screen a customer for targeted financial sanctions before the service starts
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- From the customer record, list the customer, each beneficial owner, each person on whose behalf the service is received, and each person acting for the customer, with the spelling variants already on the file. Leave the list-check result blank. The tool does not say that a person is or is not designated.
- What the lawyer must review
- The lawyer decides whether anyone is designated and what happens to assets the practice holds. Act sections 28(2)(e) and 30 and Rules section 5-3 require the practice, before the designated service starts, to establish on reasonable grounds whether the customer, a beneficial owner (except in limited circumstances the page does not spell out), a person on whose behalf the service is received, or a person acting for the customer, is designated. The check is against the current DFAT Consolidated List, including alternative spellings. The same people are checked again if they become designated during the relationship. The practice must not make assets available to a designated person, or deal with assets they own or control, without a sanctions permit. Assets they own or control must be frozen. Do not return assets held for them without a permit. If the practice holds or may hold a frozen asset, AUSTRAC expects contact with the Australian Sanctions Office and a report to the Australian Federal Police as soon as practicable. A reasonable suspicion of information relevant to a sanctions contravention must go into a suspicious matter report. This task stops at the screen, the freeze and those contacts. It does not write that report. The limited beneficial-owner exception was not set out on the page, so the lawyer reads the Act before leaving a beneficial owner off the screen.
- Written for / version
- US
Open a jurisdiction version of this task to see which instruments apply: US
Who does what
| Role | What they do |
|---|---|
| Assistance | From the customer record, list the customer, each beneficial owner, each person on whose behalf the service is received, and each person acting for the customer, with the spelling variants already on the file. Leave the list-check result blank. The tool does not say that a person is or is not designated. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Use the Consolidated List current on the day of the check, not a saved copy of unknown date.
- Include beneficial owners, persons on whose behalf the service is received, and persons acting for the customer, unless the lawyer has read the limited exception and applied it.
- On a match, do not return assets and do not keep acting unless a sanctions permit is held.
- Do not write the suspicious matter report in this worksheet.
Sources
These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.