Identify the relevant people
Section 28 requires the business to establish whether specified people connected to the customer are designated for targeted financial sanctions. It includes the customer, beneficial owners, persons on whose behalf the service is received and persons acting for the customer. Applicable Rules can modify how particular matters are established.
The Act's definition links designation to the Australian sanctions legislation. A commercial database can provide information, but its label is not itself the legal definition. This page concerns the customer-check process. It does not maintain a current designation list or describe all sanctions regimes and restrictions.
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006: Sections 5 definition of person designated for targeted financial sanctions and 28(2)(e)
- AML/CTF Rules 2025: Section 5-3
- Identify relevant persons
Include the customer and other persons required by the applicable provisions.
- Resolve a possible match
Compare appropriate identifying information; a similar name alone is not conclusive.
- Check the restriction
Assess the relevant asset and dealing prohibitions through the approved process.
A screening result needs a decision
A potential sanctions restriction is not a risk score that can be averaged away. This is a review sequence, not permission to deal with assets.
Follow the process from top to bottom.
A match needs the right response
Rules 5-3 requires policies addressing prohibited asset availability to designated persons and prohibited dealings with assets they own or control under the relevant Acts. This is different from merely assigning a higher customer risk score. A process must not treat a potential legal restriction as something a low overall score can cancel.
Check identity and the actual designation before reaching a conclusion. A shared name may concern another person. Conversely, a check limited to the named customer can miss another relevant person. The business needs an escalation path for unresolved matches and questions about restricted assets.
Worked example: a similar company name
A fictional screening result shows a company with a name similar to the customer. The result has a different place of formation and incomplete identifying details. The reviewer should examine appropriate information to determine whether it is the same entity, rather than approving or rejecting the customer on the name alone.
If uncertainty remains, the file should show that uncertainty and the controlled next step. This example does not determine what any real sanctions law permits. It illustrates why match resolution, designation and the proposed dealing are separate questions that need evidence.
Test the workflow before a live case
A practical control test uses fictional matches to check who receives the alert, who can resolve it and whether a transaction can proceed while a material issue remains unresolved. The test should include a match on a relevant associated person, not just the customer name.
Record the evidence for dismissing a false match and the basis for any further decision. Do not imply that a clear screening result certifies all AML compliance or covers every trade restriction. This page's narrow purpose is to help connect customer identification to sanctions-related controls. Specific legal advice may be needed to resolve a real restriction or permit question.