Jordanian Bank Adopts Stringent Sanctions Compliance Program to Mitigate Risks
AMMAN - The Bank of Jordan’s Commitment to Compliance
The Bank of Jordan has implemented a comprehensive sanctions compliance program to ensure that it is in full compliance with international regulations and decisions issued by the United Nations Security Council, as well as those imposed by countries where the bank operates.
A Zero-Tolerance Approach
The program aims to prevent any form of non-compliance with international sanctions programs. The bank has adopted a zero-tolerance approach towards any violations and has put in place measures to detect and report any suspicious transactions.
Key Measures Implemented
- Refuses to deal with individuals or entities listed by the UN Security Council
- Freezes assets of governments, agencies, or institutions subject to sanctions
- Prohibits transactions with prohibited countries
- Complies with sanctions imposed by OFAC (US Department of Treasury) and the European Union
Independent Compliance Function
The bank has established an independent compliance function within its organizational structure, which is responsible for:
- Verifying the application of the compliance program
- Following up on international updates and amendments
- Using automated systems to provide an up-to-date database of individuals and entities listed on embargo lists
- Integrating with customer onboarding channels to ensure that new clients are not listed on international embargo lists
Continuous Verification Process
The bank also has a continuous verification process in place to detect any pre-existing or new customers who may have been listed after account opening. The implemented automated system provides alerts in case of any matches with sanctioned entities or individuals, which are then investigated by the compliance department.
Clear Work Procedures
Clear work procedures have been established for handling clients who become listed on embargo lists, including:
- Escalating and reporting processes following discovery
- Verifying parties to financial transactions before their execution
- Implementing an online safe-watch system that scans all fields of SWIFT messages for the existence of any listed individuals or entities
Employee Training and Internal Audit
The bank provides continuous training programs for employees of all managerial levels, including the board of directors, to ensure that they are aware of their responsibilities under the sanctions compliance program.
Additionally, the bank conducts continuous examination processes to verify compliance of all employees with the requirements of the International Sanctions Compliance Program. Internal audit programs are also in place to independently verify the adequacy of procedures.
Periodic Circulars and Risk Awareness
The Bank of Jordan issues periodic circulars across its banking group containing the names of countries with high risks, in accordance with Security Council resolutions and international sanctions programs.