19. The senior staff member should: a. take the measures necessary to ensure compliance with …

The senior staff member should:

• a. take the measures necessary to ensure compliance with Section 4.2 on the restrictive measures exposure assessment;
• b. take the measures necessary to ensure compliance with Section 4.3 on effective re-strictive measures policies and procedures;
• c. provide regular and adequate information to the management body to enable it to carry out its functions as defined in Section 4.1.1 and Section 4.1.2 Management in-formation should at least include:
• i) changes to the financial institution’s restrictive measures exposure and the outcome of the financial institution’s restrictive measures exposure assessment;
• ii) changes to restrictive measures regimes and their impact on the financial institution;
• iii) statistics and information relating to:
• ▪ the number of alerts generated;
• ▪ the number of alerts awaiting analysis;
• ▪ the number of reports submitted to the relevant national authority competent for the im-plementation of restrictive measures¹¹ and/or to the competent supervisory authority as required by the applicable laws;
• ▪ the average time between the true positive match and the report submitted to the rele-vant national authority competent for the implementation of restrictive measures and/or to the competent supervisory authority as required by the applicable laws;
• ▪ the value of frozen funds, frozen economic resources¹² and the nature of those assets, held at the financial institution;
• iv) information on human and technical resources and the adequacy of those resources in light of the financial institution’s restrictive measure s exposure;
• v) deficiencies or shortcomings identified in relation to the financial institution’s re-strictive measures policies, procedures and controls, including observations pro-vided by competent authorities for the supervision of policies, procedures and con-trols for the implementation of restrictive measures;
• vi) cases of violation and of circumvention of restrictive measures and the reasons for those violation and circumvention;
• vii) proposals on how to address any changes in regulatory requirements or in restric-tive measures exposure, or any deficiencies or shortcomings in the financial institu-tion’s restrictive measures policies, procedures or controls that have been identified and cases of violation and circumvention of restrictive measures that have been identified.
• d. report all violations of restrictive measures to the relevant national authorities compe-tent for the implementation of restrictive measures and/or to the competent supervi-sory authority as required by the applicable laws;
• e. cooperate effectively and constructively with relevant national authorities competent for the implementation of restrictive measures and competent supervisory authority as required by the applicable laws.

¹¹ https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-re-sources_en#contact.

¹² See Article 2, point (5) and (6) of Directive (EU) 2024/1226.

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

3. Related Standards

• EBA -

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