GCBA-09 · v1.0 · Public Draft

Sanctions, AML and Legal Compliance

Basic sanctions screening and anti-money-laundering expectations.

Number
GCBA-09
Version
1.0
Published
2025-01-01
Next review
2026-01-01

Purpose

Reduce the risk of facilitating unlawful transactions.

Scope

  • All client and counterparty relationships.

Core requirements

  • Screen clients and counterparties against applicable sanctions lists.
  • Apply AML measures proportionate to jurisdiction and risk.

Examples of acceptable practice

  • Documented screening at onboarding and material changes.

Examples of problematic practice

  • No screening of high-risk counterparties.

Jurisdiction notes

  • Sanctions regimes evolve rapidly; local counsel is essential.

Related knowledge

Change history

VersionDateNote
1.02025-01-01Initial public draft.
This standard is educational and does not constitute legal advice. Members must comply with applicable law and regulation in every jurisdiction in which they operate.
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