The Notice reminds FIs and DNFBPs in particular of their obligations when a Listed Person is de-listed, including:

– Making previously frozen funds or assets available to the former Listed Person;

– Ongoing record-keeping requirements after targeted financial sanctions have been lifted;

– Ongoing obligations to conduct look-backs to identify third-parties who may have been owned, controlled, acting on behalf of or under the direction of the former Listed Person; and

– The obligation to self-report any previous oversights in compliance with targeted financial sanctions.

Please see the Notice published by Financial Intelligence Unit Belize at https://fiubelize.org/ .

Andrew Dalip is an attorney/international consultant in AML/CTF/CPF, Sanctions and Environmental Law in Diego Martin, Trinidad and Tobago