Sanctions Compliance Checklist in Jordan: Bank of Jordan Takes a Zero-Tolerance Approach
The Bank of Jordan has implemented a robust sanctions compliance program to ensure its business operations are in line with international regulations and decisions issued by the United Nations Security Council, ratified by the Hashemite Kingdom of Jordan. This comprehensive program covers all bank members, including foreign branches and affiliated companies.
Key Components of the Program
The Bank’s Sanctions Compliance Group Policy, approved by the board of directors and circulated to all employees, outlines the following key components:
- Refusal to Deal with Listed Individuals or Entities: The Bank refuses to deal with individuals or entities listed in accordance with UN Security Council decisions.
- Immediate Asset Freezing and Notification: Assets of governments, agencies, individuals, or institutions subject to sanctions regulations are frozen immediately, and notification is sent to the Technical Committee for the Implementation of Security Council Resolutions.
- Prohibition on Transactions Involving Prohibited Countries: The Bank prohibits transactions involving specific economic and commercial activities in countries subject to sanctions.
- Compliance with OFAC and European Union Sanctions Programs: The Bank complies with Office of Foreign Assets Control (OFAC) and European Union sanctions programs.
Implementation and Monitoring
To ensure effective implementation, the Bank has established an independent function within its Compliance Department, responsible for:
- Verifying the application of the program
- Following up on international updates
- Conducting continuous examination processes to verify employee compliance with the International Sanctions Compliance Program
- Implementing internal audit programs to independently verify procedures taken by the Compliance Department
Automated Systems and Customer Onboarding
The Bank uses automated systems to provide real-time data on individuals and entities listed on embargo lists. The system integrates with customer onboarding channels to prevent new clients from being listed on international sanctions lists, and continuously verifies existing clients to ensure they have not been listed after account opening.
Work Procedures and Escalation
In the event of a match between client names and sanctioned entities or individuals, the system automatically generates alerts for further investigation by the Compliance Department. The Bank has clear work procedures outlining actions to be taken in case of a listing on embargo lists, including escalating and reporting processes.
Continuous Training and Awareness
The Bank conducts continuous training programs for employees at all managerial levels, including the bank’s board of directors, to ensure awareness and understanding of the program’s requirements. This includes periodic updates across the bank’s group, containing names of countries with high risks according to Security Council resolutions and international sanctions programs.
Conclusion
By implementing a robust sanctions compliance program, the Bank of Jordan demonstrates its commitment to ensuring its business operations are in line with international regulations and decisions. The program’s key components, automated systems, and continuous monitoring and training ensure that the Bank takes a zero-tolerance approach to sanctions non-compliance.