As the Chief Sanctions Officer of a small Canadian Bank, you arrive at work one morning to find a voice message from an analyst on the AML Compliance team, saying they had an escalation for your review. You log into the system in order to review the escalated profile and saw that an analyst from your department had made notes stating the account should be frozen, until a confirmation could be made that the client was not a true sanctions match. In order to complete the review and the determination, you opened your sanctions tool KYC2020 and reviewed the client's name and details against the information in the database.

The client account details (your KYC files) are as follows:

Name: Angel R. Rijo

DOB: July 16, 1950

Address: 100 Church Street, Unit 1702, Barrie, ON

Employment: Retired

Respond to the following questions using the information above:

1. Provide a brief description of what a sanctions regime is and whether you think it serves a valid purpose. US and Canadian sources are considered valid responses but must be properly referenced.

2. Access KYC 2020 and use it to evaluate the potential match (if more than one, identify and evaluate 2 matches you considered to be most relevant).

a. Search via exact match and provide the best possible match if any. Please note, may not be the first match nor have the highest match score; and

b. Search via exact match and provide the best possible match if any. Please note, this may not be the first match nor have the highest match score; and

c. Search via fuzzy logic and provide first 2 results if any.

d. All search results should be evidenced by appropriate screen shots.

3. Were you able to make a determination as to whether your client was in fact the SDN listed individual? If so clearly state whether you believe the decision by the analyst was an error and whether an apology should be made to the client.

4. What pieces of information did you rely on to arrive at your decision?

5. List any websites you could go to in order to obtain additional on sanctioned entities.

Later in the month, you were asked to provide your opinion on the efficiency of KYC 2020 and whether your bank should continue to use it or migrate to Thomson Reuters World Check.

• Students are asked here to provide an evaluation of KYC 2020.
  • Because you may not have been exposed Thomson Worldcheck previously, conduct an open-source search to identify information on this solution to be used in your comparison.

Guidance on Project

In providing your evaluation, students are expected to include screen shots of the tool the supports their decision and demonstrates their understanding of how to use KYC2020 in an investigation, as well as to provide a clear and succinct rationale for their final decision. If you are unable to make a conclusive determination, please indicate the information you would need in order to do so.