Response to consultation on Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures
Question 1: Do you agree with the proposed provisions? If you do not agree, please explain how you think these provisions should be amended, and set out why they should be amended. Please provide evidence of the impact these provisions would have if they were maintained as drafted'?
In general the consultation paper is comprehensive and covers all areas of concern.
I have a comment on the second set of guidelines on paragraph 17 referring to the type of customer information that should be screened. As per the draft guidelines, if i understood this correctly, PSPs and CASPs will be asked to screen names both in the original and transliterated format. If this requirement refers to the customer data in an institution's systems, this is normally not available in both the original and transliterated Latin format. It is usually kept only in the transliterated Latin format. For a PSP or CASP with international clientele it is also difficult to keep systemic records in different languages within the institution's systems. In this respect, the daily screening of client data against sanctions list can only be performed using the Latin version of the clients' names. In my opinion, the required screening should be mandatory in the Latin version of the clients' names, and on a risk based approach, in some other languages which may be important, according to the geographical exposure of each institution.