The Office of the Superintendent of Financial Institutions has issued an information bulletin to help federally regulated and other financial institutions meet their obligations under the United Nations Suppression of Terrorism Regulations.

It explains how banks and others should deal with issues such as freezing the property of people and groups that have been listed as having links to terrorist groups. If a person whose property was frozen by mistake has not been able to resolve the matter with his or her institution, that person may apply to the Minister of Foreign Affairs for a certificate confirming that they are not a suspected terrorist. A financial institution may also apply for the issuance of a certificate with the consent of its client.

OSFI says that the Department of Foreign Affairs and International Trade intends to publish documentation that would include several improvements to the blacklist: separating individuals from entities, identifying the family name, the first name and the middle name, adding additional information about listed persons where available.

It notes that financial institutions must make their own determination as to whether they are dealing with a “listed person”. Merely identifying the same name is not sufficient. Institutions must conduct due diligence in order to satisfy themselves that a person whose name is the same as, or similar to, a name covered by the regulations is actually a listed person.

Under the regulations, financial institutions are not required to report on property related to accounts that have been closed or contracts that no longer produce any effect. However, institutions are encouraged to communicate this information to the RCMP as it may be of assistance to their investigations.