Financial sanctions breach response form and action plan

The following Risk & Compliance precedent provides comprehensive and up to date legal information covering:

  • Financial sanctions breach response form and action plan

Financial sanctions breach response form and action plan

    1. 1

      General information

      Date[Insert date]
      Name of person completing this response form and action plan[Insert name]
      Date sanctions breach report form received[Insert date ]
      Name of person who submitted the sanctions breach report form[Insert name]
      [Customer OR Client] name and reference
      (If applicable)
      [Insert name and reference]
    1. 2

      Investigation and result

      Have you investigated the circumstances as set out in the breach form?
      Set out steps taken to investigate the circumstances
      ☐ Yes
      ☐ No
      [[Insert details]]
      Has an actual breach been identified?☐ Yes—continue to section 3
      ☐ No—continue to section 4.1 and explain in detail in the conclusion why no breach has occurred
    1. 3

      Actions following breach

      Guidance: once a breach has been identified it is important to take the necessary steps to contain it and to assess the possible consequences following the breach.

      1. 3.1

        Immediate steps and detailed assessment

        Has the transaction been suspended?☐ Yes
        ☐ No—provide details
        [[Insert details]]
        Ensure you do not return the funds to the sanctioned entity or person
        Have sanctions been violated in other jurisdictions?☐ Yes—provide details
        ☐ No
        [[Insert details]]
        What civil/criminal penalties might result from this breach?[Insert details]
        Do we need to seek external advice?☐ Yes—provide details
        ☐ No

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