Federal Circular No. 18/2021 On the Lawyers’ Implementation Mechanism to Report Clients Listed on International or Local Sanctions Lists

Article 21(5) of Cabinet Decision No. 74/2020 on the Terrorist Watchlists System and the application of Security Council Resolutions relating to Preventing and Countering Financing Terrorism and Leveraging Non-Proliferation of Weapons, and the Relevant Resolutions, compels lawyers - in their capacity as members of non-financial businesses and professions - to report immediately upon identifying any match with persons or entities listed on international or local sanctions lists, or upon suspecting that a client is listed or is connected to a listed person, and they shall report any attempted transactions conducted by the client or listed person.

In order to facilitate compliance by the persons subject to the provisions of the aforementioned Cabinet Decision in meeting their obligations stated above, two new features have been added to the (goAML) platform, considered the unified platform designated for reporting any transactions or persons linked to international or local sanctions lists, namely:

  1. Funds Freezing Report. (FFR)

  2. Partial Name Match Report. (PNMR)

This enables the direct submission of reports to the Executive Office of the Committee for Goods and Materials Subject to Import and Export Control.