First Line of Defense

Within the governance structure of a sanctions compliance program, the first line of defence (also referred to as the “front line”) includes relationship managers and other customer-facing employees who are closest to the customers and counterparties during the onboarding and contracting phase of relationships. The first-line defence ensures adequate information is obtained to screen customers, owners, and controllers effectively. In general, the first-line defence owns and manages the collection of SDD information.

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