Page 49 - 《期货和衍生品行业监管动态》（2022年合集）

期货和衍生品行业监管动态

ensures financial sanctions are properly understood, enforced and implemented in the
UK. If you know, or have ‘reasonable cause to suspect’ that you are in possession or

control of, or are otherwise dealing with, the funds or economic resources of a

designated person you must:

 freeze them

 not deal with them or make them available to, or for the benefit of, the

designated person, unless:

 there is an exception in the legislation that you can rely on; or

 you have a license from OFSI

 report them to OFSI

Steps to reduce the risk of sanctions evasion via cryptoassets

As set out in communications from the FCA, cryptoasset firms must take steps to

ensure they are compliant with their legal obligations in relation to sanctions.

Controls developed to identify customers and monitor their transactions under

the Money Laundering Regulations 2017 can help with compliance, but firms will

need to implement additional sanctions specific controls as appropriate. In particular,

firms should consider:

 updating business-wide and customer risk assessments to account for

changes in the nature and type of sanctions measures

 ensuring that customer onboarding and due diligence processes identify

customers who make use of corporate vehicles to obscure ownership or source of

funds

 ensuring that customers and their transactions are screened against

relevant updated sanctions lists and that effective re-screening is in place to
identify activity that may indicate sanctions breaches

 identifying activity that is not in line with the customer profile or is

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