| 1. | Screening. VASPs must screen all clients and transactions against lists of designated Entities maintained under—
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| | a. | the UNSC sanctions frameworks; and |
| | b. | Federal AML-CFT Laws.
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| 2. | VASP are required to—
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| | a. | implement automated screening systems to identify and flag transactions involving designated Entities from the UNSC sanctions frameworks or Federal AML-CFT Laws; and |
| | b. | ensure that such systems are updated regularly with the latest sanctions lists and operate in real-time.
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| 3. | Freezing. VASPs are required to—
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| | a. | take immediate action to freeze any assets, including Virtual Assets and/or money, associated with individuals or entities identified as designated Entities under the UNSC sanctions frameworks or Federal AML-CFT Laws; and |
| | b. | ensure that no withdrawals, transfers, or use of the frozen assets occur during the freezing period.
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| 4. | VASPs must establish and enforce internal policies and procedures to—
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| | a. | immediately freeze any assets, including Virtual Assets and/or money, upon detecting a match with a designated Entity; and |
| | b. | maintain records of all freezing actions and associated transactions for a minimum of eight (8) years.
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| 5. | Prohibition of transactions. VASPs must block and prohibit—
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| | a. | any transactions involving individuals, organisations, or entities listed under the UNSC sanctions frameworks or Federal AML-CFT Laws; and |
| | b. | any attempts by clients to bypass the UNSC sanctions frameworks or Federal AML-CFT Laws.
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