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Sanctions, UAPA and WMD screening

AML programmes must include sanctions and targeted-financial-sanctions controls under applicable UAPA, WMD and regulatory directions, with freezing and rep

Finin2min summary

AML programmes must include sanctions and targeted-financial-sanctions controls under applicable UAPA, WMD and regulatory directions, with freezing and reporting escalation.

Source review date: 4 July 2026. Read with the official text and the facts of the transaction.

Legal anchors

  • UAPA-related orders
  • Section 12A of WMD Act and related procedure
  • RBI/SEBI/FIU directions

How to analyse it

  1. Screen customers, beneficial owners and transactions.
  2. Use current lists and fuzzy matching.
  3. Escalate true matches immediately.
  4. Do not release or reject transactions outside approved procedure.

Practical illustration

A customer name partially matches a designated entity. The case requires controlled investigation, not automatic customer contact.

What can go wrong?

  • Outdated lists
  • No beneficial-owner screening
  • Tipping off

Evidence pack

  • Screening logs
  • List version
  • Match analysis
  • Freeze/report record

Decision workflow

  1. Freeze the facts and effective date.
  2. Identify the controlling Act, rule, notification, circular and jurisdictional overlay.
  3. Prepare a calculation or exposure note.
  4. Collect the evidence pack before filing, payment, signing or response.
  5. Record reviewer conclusion and assumptions.

Quick Q&A

Is the result automatic?

No. Screen customers, beneficial owners and transactions.

What is the most important control?

Do not release or reject transactions outside approved procedure.

What should be escalated?

Outdated lists, especially where money, deadlines, enforcement, personal liability or irreversible transaction steps are involved.

Official source trail

Secondary commentary may help interpretation, but it is not the source of law.

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