FINANCIAL SANCTIONS DATABASE (FSD) User Manual

Transcription

1 FINANCIAL SANCTIONS DATABASE (FSD) User Manual 1

2 Contents 1. INTRODUCTION WHAT IS THE FINANCIAL SANCTIONS DATABASE? ACTORS AND PROCESSES ROLES IN FSD MAIN WORKFLOW Encoding the legal base Encoding a sanction operation Posting information LOGIN AND NAVIGATION LOGIN NAVIGATION SEARCH FUNCTION INFORMATIVE SEARCH Operators Search results: information management OPERATIONAL SEARCH: SEARCH SANCTION OPERATIONS MENU SUMMARY INFORMATION MANAGE LEGAL BASE (ENCODER, VALIDATOR) SEARCH FOR A LEGAL BASE CREATE NEW LEGAL BASE INITIAL LEGAL BASE VS LINKED LEGAL BASES VALIDATING THE LEGAL BASE UPDATE / DELETE AN EXISTING LEGAL BASE Update the legal base Delete a DRAFT legal base ADD CORRIGENDUM TO LEGAL BASE MANAGE SANCTION OPERATIONS (ENCODER, VALIDATOR) SEARCH FOR SANCTIONS OPERATIONS VIEW SANCTIONED ENTITY(IES) DETAILS TYPES OF SANCTION OPERATIONS ALL SEARCH / CREATION Entities and versioning Multi-track legal base and entity versioning Record entity details Modify entity s details AMENDMENT SUSPENSION SANCTION OPERATION RE-APPLICATION DELISTING SANCTION OPERATION ONGOING OPERATION

3 7 WORKFLOW SEND SANCTION OPERATION TO VALIDATION (ENCODER) VALIDATE SANCTION OPERATION (VALIDATOR) SEND BACK FOR CORRECTION (VALIDATOR) CANCEL SANCTION OPERATION (ENCODER) INVALIDATE SANCTION OPERATION (PUBLISHER) MANAGE INVALID SANCTION OPERATIONS: CONFIRM INVALID/RE-VALIDATE (PUBLISHER) Confirm invalid Re-valid invalid sanction operations ACTIVE WORKFLOW MANAGE DRAFT MANAGE TO VALIDATE MANAGE VALID MANAGE INVALID MANAGE ALL POST INFORMATION (PUBLISHER) PREPARE TO POST POST INFORMATION POSTING HISTORY (ADMIN, PUBLISHER) CORRECTIONS OF POSTED SANCTION OPERATIONS (INFORMATION QUALITY MANAGER) SEARCH FOR THE POST SANCTIONS OPERATIONS TO BE CORRECTED NOTIFICATIONS MANAGE BUSINESS SPECIFIC DATA (ADMIN) TASKS MANAGE INFORMATION Create new item Edit an existing item Disable/Enable an existing item Delete an existing item HELP GLOSSARY

4 1. Introduction 1.1 What is the Financial Sanctions Database? The Financial Sanctions Database is an encoding interface which allows the creation of exchange files and results in a repository of data about financial sanction operations concerning natural persons or entities, subject to a published legal base. The purpose is to make available public information, provided by the Council or the Commission and published in the Official Journal of the European Union (OJ) by OPOCE, about currently sanctioned entities, so that legal obligations concerning these entities can be accomplished by external actors (the most important ones being the banks). The date of entry into force of the regulation is of utmost importance for banks as this is the start date of their legal obligations. The database must be updated as soon as new information is available in the Official Journal (OJ) publication. Exchange files will contain the updated list of the sanctioned entities and the information is available on the European External Action Service (EEAS) website and on a separate ftp site. General public and Economic operators accessing the EEAS web site can consult or download information about entities that are subject to financial sanctions. The main economic operators are the banks. There are 4 banking federations which should be mentioned: FBE the Banking Federation of the European Union GEBC the European Association of Cooperative Banks EAPB the European Association of Public Bank and Funding Agencies ESBG the European Saving Banks Group. 1.2 Actors and processes The European Council or the European Commission provides regulations which represent the legal base to apply sanctions to different entities, with information coming from different sources. These are sent to the OPOCE to be published in the OJ. The FPI (Foreign Policy Instrument) is in charge of providing banks only with information that is published in Official Journal. It extracts information from the list of sanctioned entities that is annexed to regulations and it enters it into the FSD application. Regulations are correlated between them, so that: a first regulation (initial) is established per contry/regimen of sanctions application. 4

5 later on, further amendments/judgments may follow to amend the information related to sanctioned entities, to delist some of them or to re-activate others. The correlation of the initial legal base and its further amendments is what we call the track. The track is therefore the temporal sequence of legal bases updating sanction operations. Each time a new legal base updates information on sanctioned entities, you will be able to register it under the initial track, or in case of new regulation to create a new one. The track keeps a trace of all updates of legal bases amending information about sanctioned entities. The various regimes for which sanctions are applied are recorded as programmes in the system for convenience of managing regulations. For each programme, there is at least one initial legal base (regulation). The registration in FSD may begin before information is published in OJ, but no data is allowed to be validated and posted before they are published on OJ. Before validation, the information encoded is checked by the FPI user against the information published in OJ. FSD allows FPI users to encode legal bases and resulting sanction operations (entities) : 1. encoding of information in an initial version (draft) 2. checking information against the published legal information (validation) 3. formatting these data in files to be made the available to the public (posting). Please find below a view of the overall process s workflow: 5

6 1.3 Roles in FSD A user is allowed to manage information only if he was granted the necessary permissions in the xsec platform. In order to ask for permissions, please send an to the FPI CRIS USM mailbox. At least two persons are involved in the preparation of drafts, requiring the registration of information and its validation. Persons having both roles should not perform both operations on the same drafts. Nevertheless, from a technical perspective, the ENCODER, VALIDATOR and PUBLISHER roles are cumulative: they can be all assigned to a single user. If the same users performs tasks related to 2 different roles, a justification must be provided, which is called derogation within the FSD application. You will find below the main active actors who can manage information in the FSD system: Role ENCODER Task Recording the information published on the OJ, in status DRAFT: legal base (registration and validation) sanction operation and its entity(ies) details (registration only). VALIDATOR PUBLISHER Validating the information entered by the Encoder (sanction operations). If it is necessary to correct existing records, the Validator can do this for records in TO BE VALIDATED or VALID status. Preparing to post and posting (publishing) VALID sanction operations on: the EEAS web site, a ftp server, specifically set to make information available to economic operators and to the general public ABAC Workflow recovers the files available on the ftp server. The system can send a notification by to tell some actors that a new publication has been done, but files are not sent automatically. ADMINISTRATOR VIEWER INFORMATION QUALITY MANAGER Managing business specific data (like Programmes, Subject types and Legal base types) in order to ensure a proper classification of data within the application. Consulting information about sanctioned entities in read-only mode (no editing rights). Checking the last correct sanction operation when wrong information was sent to external actors through the posting process and selecting it for posting. 6

7 1.4 Main workflow There are 3 main actions which are carried out in the process when entering a new sanction/corrective one: Encoding the legal base The sanction operations on entities are substantiated (or credited) by a legal base which must be associated to the sanction. The legal base can be a regulation, a judgment or an amendment. For each programme (corresponding to a country or regimen) there is usually a Council/Commission regulation subject to which entities are sanctioned. This is the initial legal base. Further on, sanctions or modifications to existing sanctions are made based on amendments/ judgments to existing initial legal bases (regulations). These amendments are linked to the initial legal base. This is what we call the track the sequence of legal bases subject to which new sanctions are created or existing sanctions are modified (information is added, suspended, de-listed, re-applied etc). This legal base can be entered in the FSD by the ENCODER/VALIDATOR initially in DRAFT status, before its publication in the Official Journal (OJ), to allow the encoding in parallel of the resulting sanction operations. After its publication into the OJ, the legal base publication information is entered and its status is changed into VALID Encoding a sanction operation Subject to a published legal base, FPI introduces in the application new sanctions on new entities or modifications on existing sanctions, under a different programme for instance. The encoding of the legal base stipulating the sanction is nonetheless, a preliminary step (in at least DRAFT status). Once a sanction operation is introduced, an associated entity version (of the sanction as well) is created from scratch or from the previous one for an already existing entity (and its sanction). The compliance with what is published in Official Journal of the EU (OJ) is guaranteed by an approval workflow of the sanction operation and the associated entity information entered in the system. The sanction operation can however be validated only once the associated legal base was published and hence rendered VALID! The information on sanction operations is entered by the user with ENCODER and VALIDATOR permissions Posting information Information on the VALID sanctioned entities and its related legal base track is made available on the European External Action Service (EEAS) website and on an ftp site for consultation purposes or for carrying out the freezing of sanctioned entities financial assets as an obligation imposed by law to 7

8 banks. This is done by the user having a PUBLISHER role and the process comprises 2 steps: the preparation to posting and the posting operation. 8

9 2 Login and navigation The application can be accessed via an internet browser, by clicking on the following link: Login Any user who manages data in the FSD application must connect by typing their ECAS username and password (masked) and clicking on the Login button: 2.2 Navigation When connecting to FSD, the home page below is displayed. In the right-hand corner: a link to the Legal notice, Contact, as well as the link to Logout are displayed your login and role(s) are displayed. If you log out, you can log in again by clicking on the Login link available in the right-hand corner: 9

10 The left navigation menu is made up of seven main items, some of them having sub-menus: Search: general search menu for consulting purposes. Summary information: allows all users to consult the current status of legal base and sanctions operations and the user s activity within the workflow. Legal Base: search, encoding and validation of legal bases triggering sanction operations. 10

11 Sanction operations: entering new sanction operations or modifying existing ones (and their entities). Active workflow: allows users with permissions viewing the sanction operations currently in the workflow, waiting to be sent to a following step. Post information: allows publishing the sanctions operations on external sources. Notifications: displays the list of the internal notifications of FSD. Business specific data: allows managing data used across all the operations that can be performed within the application. 11

12 3 Search function All main actors can search for information, provided they have the required permissions. There are two types of searches: Informative search: this search function allows the users to find an entity that is subject to financial sanctions for consultation purposes. This is done via the Search menu. Operational search: for performing operations on the sanctions operations themselves or on the sanctioned entities versions. This allows users with editing rights to look for existing sanctioned entities, to perform sanction operations and advance in the workflow for sanction operations. This can be done via the Search sanction operations menu. For further details, please see the chapter Informative search The informative search can be done via the Search menu. It allows you to look for sanctioned entities according to certain criteria, for example under a specific legal base (not under the whole track) or programme, for consultation purposes only. If you want to look for sanction entities under a whole track (all inter-linked legal bases), please use the Search sanction operations sub-menu. For further information, see the related chapter 6.1. In the left navigation, click on the different search criteria: menu. An empty screen appears with You can search sanctioned entities by the following criteria: Name of the sanctioned entity ("whole name" field of Name and aliases details) Logical ID of the sanctioned entity Document number of Identification document Subject type of the sanctioned entity 12

13 User who managed the sanction operation/sanctioned entity last time Programme name. Multiple choice is allowed: to do this, select a first programme then click the field empty space, to have the drop-down list of all programmes. Legal base list (Multi-choice is allowed, by selecting legal bases in the list. This list can be filtered either by entering its Number/Titles, entry into force range of dates, or programmes). Search is not case sensitive. If you want to clear all the criteria that you filled in, please click on the Clear all button. To launch a search, click on the Search button. A maximum of 1500 records will be displayed. The user is informed through the following message: "The maximum number of record has been reached, please refine your search" Operators To refine the search, 3 search operators are available in the right-hand corner of the screen. 1. Match all of the following: all the criteria are taken into account when retrieving the search results. For instance if I try to find a certain entity sanctioned in a specific programme (and this is not the case), the system will return 0 results: 2. Match any of the following: at least one criterion is taken into account when retrieving the search results. Using the same criteria as for the 1 st case, the system will return all sanctioned entities with the name above and all sanctioned entities under the AFG programme: 13

14 3. Strict mode: if you tick this box, the system displays in the search results only records that match exactly what was entered in fields of type 'free text box' (with the exception of Logical ID field). If the checkbox is un-ticked then the system displays all values that contain the entered value. *Operator When you enter more than one keyword that are supposed to be found in the same free text field, then you can make use of the '*' operator. For example, you can find the passport, with identification number "DM ", by entering "M*5*13" as a criterion. This functionality is incompatible with the Strict mode. Extended search capability To help finding some names that are compound names, with a special characters in between, like '-', '/', '_', the system uses a configurable set of composition characters and retrieves all values that satisfy the following rule. All retrieved values that are different from the entered text only because of occurrences of any separator character, which may all be found, in whichever order, at any point of the entered text. Example: If in a free text field search criterion the user types alaqsa, the system returns records with values like: "ALAQSA", "Al Aqsa", "Al_Aqsa", "Al-Aqsa". This functionality is incompatible with the Strict mode. 14

15 3.1.2 Search results: information management Once you launch the search, the list of total results will be displayed. If we look for instance for sanctioned entities under the legal base 1033/2009, the system will display 8 existing records. The system displays a number of results, which represent the total number of the sanctioned entities under that specific legal base (not under its all track), as in the example below: The information is displayed in a table containing the header of the sanctioned entity. When clicking on the arrow in front of the head of one sanctioned entity, the row expands, allowing the user to view its details: 15

16 Sorting/filtering information In any Search screens of the application Informative Search, Search Legal Base or Search sanction operation menus - information can be sorted and filtered. The search operators are available by clicking on the small arrow next to each sub-heading of the results table, as in the example below: 1. Sort ascending: sorts in an ascending order (for instance numbers of legal bases, dates) 2. Sort descending: sorts in an ascending order (for instance numbers of legal bases, dates) 3. Columns: allows selecting which columns will be displayed in the results table: 4. Filter: allows looking for data using some additional search operators: is equal to, is not equal to contains, does not contain, starts with, ends with. Select the operator to be used, and click on Filter. To clear your choice, click on Clear : 16

17 Export function Search results can be exported in Excel format, via the Export button, available in the right corner of the screen. The export will retrieve all displayed results. Therefore you cannot select just one or several sanctioned entities for the export in Excel: The Excel document can be opened or saved. 17

18 3.2 Operational search: Search sanction operations menu Unlike the informative search, the operational search allows you to look for all sanctioned entities under the whole track of the selected "Working Legal Base" (all associated legal bases), to advance in the workflow or to do other sanction operations: For further information, see the 6.1 Search sanction operations chapter. 18

19 4 Summary information The Summary information menu allows all users to consult the current status of legal bases and sanctions operations and the user s activity within the workflow s operations. Click on the Summary information menu: A summary picture is displayed, with 3 main panes: The information can be exported in Excel format via the chapter button. For further details see 19

20 The 3 panes, which are made up in turn of several zones: I. In the first pane the following information is displayed: 1. The User details, its roles (permissions) and the tasks he can perform according to his role, for information purposes (no action is possible): 2. The total number of : a. Legal bases in DRAFT and VALID statuses b. Referenced programmes i. the most recently used programme and date of last legal base entered for that programme and ii. the less recently used programme and date of last legal base entered for that programme. c. User's actions on legal bases: number of actions performed on legal bases per user. 20

21 3. The total number of: a. Sanction operations: currently on-going of the type creation, amendment, suspension, re-applying, delisting sanction operations per status draft, sent to validation, valid, invalid, confirmed invalid, posted, wrongly posted. b. Sanctioned entities: and their status (initialized, active, inactive) and the total sanctioned entities and re-postings c. Sanction operations per FSD user. 21

22 II. In the second pane the Legal Bases in DRAFT status and those who were rendered VALID are displayed. Click on the small arrow next to DRAFT or Recent VALID to expand the list of legal bases references: III. In the third pane a summary table with all ongoing sanctioned entities versions: currently in the workflow (all statuses, except for those in POSTED status) is displayed, with their related sanction operation, legal base, programme and the user s login who did the last update. To see how to sort, filter and export information, please refer to the Search results: information management chapter. 22

23 5 MANAGE LEGAL BASE (ENCODER, VALIDATOR) Entities are sanctioned following a legal base which is published in the Official Journal (OJ). Recording the legal base information is the first step and it is mandatory before recording a sanction operation. Any creation or modification of a sanction/related entity(ies) can only be triggered by information published/to be published in a legal base that must be encoded in FSD! The user must register the legal base information before its publication in an initial version which corresponds to a DRAFT status in the FSD application. Following its publication of the legal base in the OJ, the ENCODER/VALIDATOR must enter its publication details and change its status into VALID. A sanction operation can be created or modified with a linked legal base in DRAFT status, but it can be sent for validation (DRAFT TO BE VALIDATED status) only if the legal basis s status is rendered VALID! There are 3 legal base types that can be recorded in FSD: 1. Regulation (initial legal base): there is at least one regulation for each programme. A new regulation is to be entered where there is no mention of amendment in the legal text. A new regulation can only trigger sanction operations of the type CREATION for new entity or for existing entity! 23

24 2. Amendment and Judgments to an initial legal base (to existing regulation) that can trigger all types of sanction operations. Most of legal bases to be encoded are amendments of judgments to existing regulations (initial legal bases). According to the type of legal base, the registration in FSD is different. The track is the temporal sequence of legal bases updating sanction operations. Each time a new legal base updates information on sanctioned entity(ies), you will be able to register it under the initial track, or in case of new regulation, to create a new one. The user with ENCODER or VALIDATOR permissions can record a legal base containing information about entities that are subject to financial sanctions. Please find below a diagram illustrating the workflow of a legal base: 5.1 Search for a legal base Information on the legal base can be consulted (read-only mode) by users having no editing rights. Before encoding a new legal basis, please make sure that this is a new (initial legal base, regulation), or if it is an amendment/judgment amending an existing regulation. To search for an existing legal base, click on the Search legal base sub-menu: 24

25 You can search for legal bases using the following criteria: Number/Title Programme Organization Legal base type Legal base status Remarks text User who last updated legal base information Range of dates of entry into force. Select your criteria and click on the Search button. To empty the criteria, click on Clear all : The system displays retrieved information in a table with the below headers.: Legal base number/title, status, Programme Date of creation Publication date Entry into force date 25

26 Last user who updated its information. Click on the small arrow on the top of the results, to expand the list on the whole pane: To see how to sort, filter and export information, please refer to the Search results: information management chapter. 5.2 Create new legal base Sanctioning entities can be triggered by information published/to be published in a legal base that must be encoded in FSD! Recording the legal base information is the first step and it is mandatory before recording a sanction operation (initial or corrective). The user must register the legal base information before its publication in an initial version: DRAFT status. Following its publication of the legal base in the OJ, the ENCODER/VALIDATOR must enter its publication details and change its status into VALID. There are 3 legal base types that can be recorded in FSD: 1. Regulation (initial legal base): there is at least one regulation for each programme (country or regimen). A new regulation is to be entered where there is no mention of amendment in the legal text. A new regulation can only trigger sanction operations of the type CREATION for new entity or for existing entity! 2. Amendment and Judgments to an initial legal base (linked to initial legal base). Most of legal bases to be encoded are amendments of judgments to existing regulations (initial legal bases). According to the type of legal base, the registration in FSD is different. To create a legal base of any type, the user chooses in FSD menu the Create legal base menu: 26

27 5.3 Initial legal base vs Linked Legal Bases The track is the temporal sequence of legal bases updating sanction operations. Each time a new legal base is published in the OJ to provide updates on sanctioned entities, you will be able to register it under the initial track, or in case of new regulation, to create a new one. The track keeps a trace of all legal bases amending information about entities that are subject to the same sanction. I. In case of legal base type Regulation, the system automatically creates a new track from scratch. In this case system displays the mention Initial Legal Base and user does not have to link the regulation to previous legal base: A new regulation is to be entered where there is no mention of amendment in the legal text. A new regulation can only trigger sanction operations of the type CREATION for new entity or for existing entity! Judgments that cancel a sanction are encoded as new legal base and normal delisting sanction operations are to be created. For judgments that confirm a sanction for instance, no action has to be taken in FSD. 27

28 II. In case of legal base type Amendment or Judgment, it means, if the legal base amends sanctioned entities referenced by a previous legal base, then the user must link the two legal bases to each other, before any sanction operation is associated to it. This is done by assigning the legal base - Amendment or Judgment - to an existing track. When user clicks on the Select button, a window opens up to allow the user to look for an initial legal base (regulation) to be linked. The window shows the list of all the initial legal bases from the respective track. This list is automatically filtered depending of the values entered into fields like programme. User can also filter it by number/title or a defined range of dates (entry into force or last update). Select the initial legal base and click on the Select button: Once the legal base linked to an initial track, a new button appears in the lower part: Show track list. If ticked, icons to all associated legal bases are displayed. Clicking on them directs you to the online published pdf document: 28

29 On the creation of an initial legal base or of an amendment/judgment, the following mandatory and optional fields must be filled in: Mandatory (for the submission of information and creation of the DRAFT legal base): Type of legal base (Regulation, Amendment, Judgment) Number/Title (mandatory, even in draft status, always editable) Programme Organization Select (track): only for Legal base Type Amendment or Judgment. Optional (but mandatory when validating the DRAFT legal base): Republishing : tick this box if the legal base is an update of the legal reference. A legal base may repeal the previous sanctioning regulation and replace it by another legal base of type 'Amendment'. In this case the amendment is flagged for Republishing' in FSD. IMPORTANT INFORMATION! Information concerning sanctioned entities must be posted to external actors in order to communicate the new associated legal basis reference, even if no sanctioned entity detail was modified. The system cannot read the content of the legal base, so it is up to the user to record the resulting proper sanction operation, where applicable: creating a creation, amendment, suspension, reapplication, delisting sanction operation. The only help that the system offer to the user is to automatically select all latest posted sanction operations (in tab Amendment of the Search sanction operation menu) for creating new amendment. The user may de-select some of the operations, where needed. 29

30 The republishing of information to update the legal base reference involves only the global xml file which will be generated after the posting. Only if the republishing legal base also amends information of a sanctioned entity (triggering a sanction operation), then posting involves the Delta xml file generated after the posting. Entry into force date: mandatory when validating the DRAFT legal base. Publication date: mandatory when validating the DRAFT legal base. Legal base URL of the published document in OJ: mandatory when validating the DRAFT legal base. Remarks Area: free text area to introduce eventual remarks/comments. This information stays internal to FSD and it is not therefore published in the files accessible to external actors. The fields marked with a star ('*') are mandatory! To be able to submit information, you must fill them out. The other fields are not mandatory, or they are mandatory only upon the validation of the legal base! The sequence of legal bases must be respected. The link to a track can only be added from the new created legal base - Amendment or Judgment. The user may change the link between legal bases (to an initial track), provided there are no sanction operations associated to the track in question. This can be done via the Change track button. This button is not available if there are sanction operations associated to the legal base. Fill in mandatory information and click on the Save button. The Create new button allows you to clear all fields and to start the registration from scratch. After clicking on the Save button, the system: creates the legal base and sets its status of the legal base as DRAFT links the legal base to an initial track, if the amendment/judgment refers to an initial legal base (regulation). 30

31 5.4 Validating the legal base Once the legal base is published in the Official Journal of the European Union, the ENCODER/VALIDATOR must enter in the DRAFT version of the legal base: the publication details (Legal base URL, Entry into force date and Publication date) and change its status to VALID. Please note that in order to sanction an entity, the legal base must be entered at least in DRAFT status. Nonetheless, in order for a sanction operation to be validated, the status of the legal base must be changed to VALID! To enter the publication details necessary for the validation, the user must search the DRAFT legal base via the Search function of the Legal Base menu: Click on the small arrow next to its number/title to view its details, and then on the arrow in the upper part of the screen, to expand its details: Click on the Edit button and introduce the Legal base URL, Entry into force date and Publication date: 31

32 Click on the Save button to register the changes: In order to validate the legal base, the ENCODER/VALIDATOR must click on the VALID button available in the lower part of the legal base details screen: 32

33 Once done, the status of the legal base changes into VALID: The user can send the sanction operation for validation in the workflow. 5.5 Update / delete an existing legal base Update the legal base To correct incorrect information, the user can always update the legal base in VALID status. After having performed a search in the Legal base menu, select your legal base and click on the small arrow next to the legal base identification number to display its details: 33

34 To correct existing information, click on the Edit button. Depending if there are linked sanction operations yet, it will be possible to modify some or all of the following fields: Type of legal base (Regulation, Amendment, Judgment) Number/Title (mandatory, even in draft status, always editable) Programme Organization Change (track) Republishing tick box, if the legal base is an update of the legal reference. Optional in Draft status, mandatory in VALID status: Entry into force date Publication date Legal base URL of the published document in OJ Remarks area. 34

35 Click on the Save button to register the changes Delete a DRAFT legal base Only legal bases in DRAFT status, with no associated sanction operations (in whichever state) can be deleted. Therefore, if you have to delete a DRAFT legal base having linked sanction operations (in DRAFT status), you will have to delete these ones first. To delete an existing legal base, click on the Delete button and confirm your choice: The legal base will be completely deleted from the FSD application. 35

36 5.6 Add Corrigendum to legal base If the Office for Official Publications of the European Communities (OPOCE) corrects information about an already published legal base and this one is already in VALID status in FSD and entities have been sanctioned with reference to it, then a Corrigendum is necessary in order to publish the new information. This corrigendum must be also introduced in the legal base in FSD. Search the VALID legal base via the Search legal base menu. When displaying the legal base s details, an Add corrigendum button is available: Once you click on it, a new window opens up. You will have to enter here then the Corrigendum URL (from the OPOCE) and its Publication date. Click on the Update button: 36

37 A new window is displayed with the initial version of the legal base, and the corrigendum information in the lower part of the screen: You are still able to edit the corrigendum url or the publication date, by clicking on the pencil icon/ x icon available next to the corrigendum: Click on save to register the corrigendum. You will receive the green confirmation message: Further on, the corrigendum may entail a sanction operation modifying information about the related sanction operations of the type CREATION, AMENDMENT and REAPPLICATION. It is up to the user to register the corresponding corrigendum to the sanction operations. To do this corrigendum, go in the Search sanction operation menu and introduce the corrigendum to the legal base as Working Legal Base: 37

38 If a corrigendum was entered for the associated legal base, the user must do a sanction operation of the type Corrigendum to the associated sanction operations of the type CREATION, AMENDMENT or REAPPLICATION. 38

39 6 Manage sanction operations (ENCODER, VALIDATOR) 6.1 Search for sanctions operations Unlike the informative search, the operational search allows you to look for sanction operations under the entire track of a legal base and it allows the user to advance in the workflow, in order to: 1. create a new sanction operation on (a) new entity or on an existing entity under a different track/programme 2. modify an existing sanction operation and its related entity(ies), starting from its last POSTED sanction operation: amend, delist, suspend, re-apply a sanction to one or several sanctioned entity(ies). In this way, the differences from information of previous operation and entity version are transparently displayed, before being posted to external actors. The operational search can be done via the Search sanctions operations sub-menu: 1. The user must enter the Working Legal base that the new sanction operations will be associated to, by selecting its number/title from a list sorted by most recent date. The list includes legal bases in both DRAFT and VALID statuses. Without selecting the legal base, no sanction operation is displayed: 39

40 2. Once the legal base selected, the system provides 7 operating tabs where different types of sanction operations are displayed: All, Search/Creation, Amendment, Suspension, Re-application, Delisting, On-going operation. Depending on the type of sanction and its status, action buttons in the right column allow the user to do further corrective sanction operations: To see how to sort, filter and export information, please refer to the Search results: information management chapter. 6.2 View sanctioned entity(ies) details To view the details of the entity(ies) of a sanction operation, the user must: select the Working Legal Base 40

41 type name (part of it, alias or full name) in the Find in page function (CTRL + F). If several entities contain the same name/alias, keep clicking on ENTER to find the one you search for select the logical ID of the sanction operation by clicking on the on the small arrow in front of it: The personal identification data extracted from the associated legal base are organized in 5 tabs: name/aliases, birth date, citizenship, address and identification documents. Click on the Name/Aliases tab. Further on, by clicking on the small arrow next to each entity you can view the details of each name/alias: 41

42 6.3 Types of sanction operations There are 2 main types of sanction operations: Newly created sanction operation Or modifications to existing sanction operations (corrective): amendment, delisting, suspension, reapplication. But for the newly sanctioned entities, whenever you do a sanction operation, since information about the sanctioned entity was already published to external actors, you must do it from its last POSTED version. Please find below an explanation of all operating tabs: 1. All: displays in this tab the list of all entities that have been created / sanctioned / delisted on the track to which belongs the selected legal base in whatever status and allows creating sanction operations of any type. Delisted entities are in INACTIVE status if they are sanctioned only in one track. Delisted entities maybe in ACTIVE status if they are still sanctioned in other tracks/programmes. 2. Search/creation: allows recording a new entity or creating a new sanction on an already existing entity. You select an entity to sanction it again in the same track only if the last posted sanction operation on this entity is of type Delisting. Before creating a sanction on an entity (new or already existing), you must search the entity via the name/alias field among all entities belonging to all possible tracks/programmes, to be sure that you are not creating twice the same entity. But you can always decide to create the entity as a brand new one, even if it exists in another track/programme, to keep it as a separate entity. 42

43 3. Amendment: allows recording a sanction that amends information about an entity. System displays in this tab, the list of all entities of the track on which it s possible to make an Amendment. 4. Suspension: allows suspending the sanction to an entity. System displays in this tab, the list of all entities of the track on which it s possible to make a Suspension. 5. Reapplication: allows recording a sanction operation that re-applies a sanction on an entity. System displays in this tab, the list of all entities of the track on which it s possible to make a Reapplication. 6. Delisting: allows recording a sanction operation delisting an entity. System displays in this tab, the list of all entities of the track on which it s possible to make a Delisting. 7. On-going operation: retrieves On-going sanction operations (at status <> Posted ) to move forward in the workflow. The diagram below explains the different possible types of sanction operations and the interactions between them: 6.4 All This tab allows users to consult all sanction operations and entities linked to the track to which belongs the selected legal base s track and to perform different actions. When clicking on it: in the top part of the right pan of the screen, all types of sanction operations are displayed Buttons are active only when user selects a sanction operation on which the operation is possible. 43

44 at the bottom part of the right pane, all action buttons which allow advancing in the workflow are displayed. Depending on the status and type of the sanction operation, buttons are active or not: Edit, Cancel, Send to Validation, Validate, Back to encoder, Invalidate, Confirm invalid. You can select several sanction operations and handle them in a single go. In the example below, to do a sanction operation on the first 2 operations, click CTRL + ENTER to select them and then click on the action button. For these 2 sanction operations in the example below (of the type CREATION) it is possible, following a legal base, to amend, to suspend or to delist the sanctioned entities: Each type of sanction operation is described in detail in the chapters

45 6.5 Search / Creation This tab allows you: to search for already sanctioned entities under a Working Legal Base (one track) to sanction an entity for the first time (new entity) or in a different track (creation for an existing entity). Before creating a sanction on an entity (new or already existing), you must search the entity via the name/alias field among all entities belonging to all possible tracks/programmes, to be sure that you are not creating twice the same entity! But you can always decide to create the entity as a brand new one, even if it exists in another track/programme, to keep it as a separate entity. In order to look for a sanctioned entity, in this tab you must enter the Working legal base. Search for the entity by typing his name/alias in the Name/Aliases field. Click on the Search button: The system displays a table with sanction operations which are associated to the last version of all the entities having the same name: However, you can select an entity to sanction it again within the same track, only if the last posted sanction operation on this entity is of type Delisting Entities and versioning A sanctioned entity is a natural person or an enterprise or an organization that is sanctioned by the EU. 45

46 When a sanction is applied for the first time to an entity, the system creates a set of data associated to the entity in the system and will assign a first version to the entity in question. Identification details of the sanctioned entity may change when a corrective sanction is published in the OJ. The entity version consists in the different set of entity s available information, contained in each legal base which triggers the sanction. Therefore, new legal bases (amendments/judgments to them) are published to update information about the sanctioned entities (add new information, delist or suspend sanctioned entities etc), all the other sanction operations are modifications to an initial version of the same entity. The system assigns different version numbers to the sanctioned entity the first time, and then to the further modifications made to it. In other words, each sanction operation concerning an entity, published in a legal base, is associated to its own entity numbered version in the system. Each version of the entity information is then processed following a workflow and finally posted to external actors. In FSD system, by design, there are as many versions of the entity as there are posted updates. For this reason in FSD it is equivalent to refer to a sanction operation or to an entity version. The system displays action buttons: New entity: To be used if the entity does not exist in the FSD application. To do this, please first search for it. Searching in the FSD system if an entity with the same name already exists in the same legal base track allows to make the user sure of executing the correct actions! When sanctioning a new entity, a related sanction operation is automatically created for the entity in question. Create for existing entity: To be used only for entities which have already been sanctioned (whose details already exist in the system), in the same or in a different legal base track, selected to create a new sanction operation. Entities can be sanctioned on different tracks/programmes. You cannot apply a new sanction to an existing entity in the same track other than if the entity was previously delisted from the track Multi-track legal base and entity versioning Entities are sanctioned following a legal base which is published in the OJ. Along the sanction operations, the status of the entity evolves, as illustrated in the following diagram: 46

47 After sanctioning for the first time an entity, further actions can be performed on a sanctioned operations and its related entity(ies): sanctioning the same entity under a different track, amending information on an entity, delisting an entity, suspending a sanction, re-applying a sanction. When sanctioning the same entity under a second different track, the system retrieves the details of the last version of that entity sanctioned under the former track. Further on, if under this second track the entity is further on sanctioned, the system copies the details of the first entity version under this second track. Therefore, the entities consecutive version are always associated to the number of sanction operations under one single track. The following diagram illustrates this multi-tracking mechanism: 47

48 6.5.3 Record entity details New entity If you click on New entity button, a window will pop up. Enter any information you consider useful into the 'Comment' field of the sanction operation (optional). The system retrieves information about the related working legal base. Click on Create button to save the record: 48

49 Once you fill in information in the first two tabs and click on the Next button, the following pop-up appears allowing you to fill the information about the entity to sanction: When clicking on the Update button, the rest of the tabs are enabled: Name/alias, Birth date, Citizenship, Address: 49

50 For each entity you can modify/delete information by using either: the 2 buttons to record changes, or to delete them: Add new or Cancel.. or for each detail in each information tab you have an editing icon to modify information or a delete icon to delete information: Go in each tab and fill in mandatory information. Click on save to record information. When a sanction operation is created on a new entity, a related first entity version will be created. Warning: the Update button only saves data in the browser memory. If you don't press the Save button, information is not sent to the server for saving! For existing entity If an existing entity is sanctioned under a different track/programme, you can do a sanction and the system will not create a new entity, but only the sanction operation. All the details of the already sanctioned entity (name, birth date etc) are recovered from the previous version, but will be provided with a new logical ID. You will be able to modify them, if necessary. Go in the Search/Creation tab, introduce the new legal base under which the existing entity must be sanctioned and search for it by Name/Aliases. In the example of the screen below, the entity with the name Vladimir Andreevich Konstantinov has already been sanctioned under the track 2015/427 under the programme Ukraine : 50

51 Select the new working legal base and your entity version and click on button. Once done, the last version of the existing entity is displayed below the sanction operation header, with the new legal base and programme information. A new sanction operation under a different track will be therefore created for this entity. Click on Save button to record data. Entity s details are displayed directly. Go in the Ongoing operations tab. The sanction will appear there in DRAFT status. Click on Edit to modify its details in every tab of the personal identification data, and then on Save to record the changes: 51

52 Personal identification data is organized in the following 5 tabs: name/aliases, birth date, citizenship, address and identification documents. You can add/modify information for each name/alias of the respective entity: For each detail you can modify/delete information by using either: the 2 buttons to record changes, or to delete them: Add new or Cancel.. or 52

53 for each entity in each information tab you have an editing icon to modify information or a delete icon to delete information: The button allows you to view in a summary pane all information entered for the sanction operation and the related sanctioned entities. Scroll down to see information about all details: The button allows you to view the list of versions of the sanction operation. Clicking the arrow on the first column will expand the row to display the details of the selected version. The list of versions contains all the existing versions of the sanction entity, even if they are ignored by the system, the version that have been cancelled or confirmed invalid are present as well in the history: 53

54 The button allows you to view all the actions performed in the workflow: last update (date and time), the status change, the user, the derogation reasons and the comments. On submission of all the mandatory information in all the tabs, the system: creates an logical ID for the details of the sanctioned entity creates a sanction operation of the CREATION type in DRAFT status sets the sanctioned entity status to ACTIVE links the sanction operation to the legal base records a new version of the sanctioned entity (to keep a track of the following updates). Once all tabs are filled in and saved, the sanction operation appears in the On-ongoing operations tab or in the Active workflow menu (Manage DRAFT tav), in DRAFT status. The user is able to advance in the workflow. Note: In the On-going tab of Operational Search, only sanction operations in the same track of the Working Legal Base are displayed. Instead, in Active Workflow, all on-going sanction operations sanctionned under all tracks/programmes are available. Depending on the sanction operation type and its status in the workflow, action buttons are available allowing you to peform actions on the sanctioned entities: 54

55 For more information please consult the chapter 9, Workflow Modify entity s details When applying to existing sanction operations described in the chapters that follow ( ) and before sending them for approval in the workflow, you may need to modify information on the sanction entity. The details to be modified, if applicable, can be found the associated working legal base regulation, amendment/judgment to existing one - and concern personal identification data. The modification functionality is visible once you have initiated the sanction operation amendment, re-application. Search for your sanction operation via the Ongoing operation tab of the Search sanction operation menu or in the different tabs of the Active workflow menu: To edit the details of the entity(ies), you can either click on the arrow of the sanctioned entity s logical id or click on the Edit button in the right column to expand its details: 55

56 A pane with its entity details is displayed and you can modify information in all 5 tabs: name/aliases, birth date, citizenship, address and identification documents. Click on Save to register the changes: 6.6 Amendment An amendment is necessary to amend information about an already sanctioned entity that has been created (CREATION), amended (AMENDMENT), or re-applied (REAPPLICATION), on its last POSTED version, subject to a legal base. Go in the Search Sanctions Operations menu. Before clicking on the Amendment tab, enter first the associated Working Legal Base. Once done, all sanctions of type CREATION, AMENDMENT, REAPPLICATION in POSTED status, associated to the last version of the sanctioned entity are displayed. The action button Amendment becomes active only if one or more sanctioned entities are selected. In case of a legal base for republishing, the system automatically selects all the sanctioned entities. 56

57 There are two types of amendment sanction operations: For standard operation This type is to be used when information is updated about a sanctioned entity following a legal base. For corrigendum A Corrigendum to sanction operation is necessary if one or more corrigenda have been encoded for the associated working legal base. If a corrigendum is published to correct some entity detail information, then a new sanction operation must be created following a legal base corrigendum. For example, if a corrigendum is correcting information of sanctioned entity that was previously created by a creation sanction operation, then an amendment sanction operation with reason "For corrigendum" must be created and posted to external actors. In the public remarks there will be a mention to the corrigendum. The legal base referenced for a sanction operation for corrigendum must be the legal base which the corrigendum is associated to. The legal base referenced for a sanction operation for corrigendum must be the legal base which the corrigendum is associated to. An action Corrigendum button is available only if a relative legal base for corrigendum was created for the respective track. Select the sanction operation/entity to be amended and click on the Amendment or Corrigendum button. A new Amendment sanction operation window with the reason For standard operation / For Corrigendum opens up: Add a comment, when relevant and click on Save: 57

58 Once the information is submitted, the system: creates a new sanction operation of the Amendment type and it sets it in DRAFT status links the sanction operation to the legal base records a new version of the sanctioned entity. The new sanction operation appears in the On-going operations tab or in the Active workflow menu (Manage DRAFT tab). Click on the Edit button to introduce the information to be amended on the sanctioned entity: Make the changes in the personal identification data (as per the legal base), by clicking on the Add new button or on the edit icon if the legal base modifies information: An edit window is displayed: 58

59 Be careful! Clicking on the Update button does not record the modifications! To record the changes, you must click on the Save button in all tabs! The new sanction operation appears in the On-going operations tab or in the Active workflow menu (Manage DRAFT tab). Once the information to be amended is saved, the amendment must be further on sent to validation in the workflow. Please consult the chapter 7, Workflow or the chapter 8 Active Workflow. 6.7 Suspension sanction operation This tab allows the encoder to temporarily suspend a sanction previously applied to an entity. This tab allows the encoder to temporarily suspend a sanction previously applied to an entity which has been created (CREATION), amended (AMENDMENT), or re-applied (REAPPLICATION), on its last 59

60 POSTED version, subject to a legal base. A suspension must be followed by a re-application of a sanction or a delisting (removal from the track)! A suspension must be followed by a re-application of a sanction or a delisting (removal from the track). Before clicking on this tab, the user must have first entered the associated working legal base. Once done, sanctioned entities for which last POSTED version of sanction operation type is CREATION, AMENDMENT, REAPPLICATION are displayed. The "Show All" check box allows viewing all the sanction operations of the track. This tick box is provided to give the user a wider perception of current situation. They show more information than strictly necessary, so that the user may become aware of possible mistakes that may have occurred before, such as delisting the wrong entity or creating twice a new entity. Select the sanction operation to be suspended and click on the Suspension button. A window opens up with optional field - Comment, to enter information about the sanction operation. The text entered in this field will not be part of data sent to external actors: Once the information is filled in and submitted, the system: creates a new sanction operation of the Suspension type in DRAFT status links the sanction operation to the legal base records a new version of the sanctioned entity. 60

61 The suspension sanction now appears in the Ongoing operation tab or in the Active workflow menu (Manage DRAFT tab). Their details cannot be modified, only cancelled or sent for validation: The suspension operation must be further on sent to validation. Please consult chapter 7, Workflow or the chapter 8 Active Workflow. 6.8 Re-application Later on, subject to a legal base, sanction can be re-applied to the same entity. This tab allows the encoder to record a sanction operation that re-applies a sanction on an entity which was previously suspended (of the SUSPENSION type only), on its last POSTED version. Before clicking on this tab, the user must have first entered the associated working legal base. Once done, sanctioned entities, for which last version of sanction operation is of type SUSPENSION and in POSTED status, are displayed. The "Show All" check box allows viewing all the sanction operations of the track. This tick box is provided to give the user a wider perception of current situation. They show more information than strictly necessary, so that the user may become aware of possible mistakes that may have occurred before, such as delisting the wrong entity, creating twice a new entity. This way you also are able to edit the just created draft sanction operation, without moving to another tab. To re-apply a sanction, select a row and click on the Reapplication button. A window opens up with an optional field Comment, to enter information about the sanction operation. The text entered in this field will not be part of data sent to external actors. 61

62 For standard operation This type is to be used when a sanction is re-applied to an entity following a legal base. For corrigendum A Corrigendum to a REAPPLICATION sanction operation is necessary if one or more corrigenda have been encoded for the associated working legal base. If a corrigendum is published to correct some entity detail information, then a new sanction operation must be created following a legal base corrigendum. For example, if a corrigendum is correcting information of sanctioned entity that was previously created by a creation sanction operation, then an amendment sanction operation with reason "For corrigendum" must be created and posted to external actors. In the public remarks there will be a mention to the corrigendum. The legal base referenced for a sanction operation for corrigendum must be the legal base which the corrigendum is associated to. An action Corrigendum button is active only if a related legal base for corrigendum was created for the respective track. Once the information is filled in and submitted, the system: creates a new sanction operation of the type REAPPLICATION in DRAFT status links the sanction operation to the legal base records a new version of the sanctioned entity. The re-application sanction now appears in the Ongoing operation tab or in the Active workflow menu (Manage DRAFT tab). Modify the personal identification details if necessary by clicking on the Edit button: 62

63 Be careful! Clicking on the Update button does not record the modifications! To record the changes you must click on the Save button in all tabs! It must be further on sent to validation. Please consult chapter 7, Workflow or the chapter 8 Active Workflow. 63

64 6.9 Delisting sanction operation A regulation may suspend (cancel) a sanction, subject to a legal base. Delisting an entity shall imply that the entity will be removed from the system for respect of privacy laws after an established period. Judgments that cancel a sanction are encoded as new legal base followed by a delisting sanction operation. This tab allows delisting a sanctioned entity, which has been created (CREATION), amended (AMENDMENT), suspended (SUSPENSION) or re-applied (REAPPLICATION), on its last POSTED version. Entities can be sanctioned on different tracks / programmes. You cannot apply a new sanction to an existing entity in the same track other than if the entity was previously delisted from the track. This tab allows the encoder to record a sanction operation delisting an entity or a group of sanctioned entities (removing sanctions from the track). If no sanction is applied anymore to the entity, the entity becomes INACTIVE when the sanction operation workflow has reached the status POSTED. Before clicking on this tab, the user must have first entered the associated working legal base. Once done, sanctioned entitiy(ies) for which last version of sanction operation type is CREATION, AMENDMENT, SUSPENSION, REAPPLICATION and in POSTED status are displayed. The "Show All" check box allows viewing all the sanction operations of the track. This tick box is provided to give the user a wider perception of current situation. They show more information than strictly necessary, so that the user may become aware of possible mistakes that may have occurred before, such as delisting the wrong entity, creating twice a new entity. For delisting, select a sanction operation and click on the Delisting button. A window opens up with optional field - Comment to enter information about the sanction operation. The text entered in this field will not be part of data sent to external actors: 64

65 In case of multiple sanction operations, information entered in these fields is set to be the same for all sanction operations. For delisting sanction operation no modification of the details of delisted entity is necessary! Once information is filled in and submitted, the system: creates a new sanction operation of the type DELISTING in DRAFT status links the sanction operation to the legal base records a new version of the sanctioned entity. The re-application sanction now appears in the Ongoing operation tab or in the Active workflow menu (Manage DRAFT tab). Their details cannot be modified, only cancelled or sent for validation. 65

66 It must be further on sent to validation. Please consult chapter 7 Workflow or the chapter 8 Active Workflow Ongoing operation This tab allows viewing and advancing in the workflow of different types sanction operations, in all statuses. It has similar functionalities with the Active workflow menu, described in chapter 10. Only sanction operations associated to one single track are displayed and can be handled. The different sanction operations of any type CREATION, AMENDMENT, SUSPENSION, REAPPLICATION or DELISTING and in all statuses appear here. Depending on the type and status, different action buttons are active in the right column bar: Edit, Cancel, Send to validation, Validate, Back to encoder, Invalidate, Re-validate, Confirm invalid. Sanction operations described in chapter 8 (Manage sanction operations (ENCODER, VALIDATOR)) go through an approval process, involving the main active actors described in chapter 1.3. Please find below the different possible actions along the workflow, as well as the evolution of the sanctions operations status: Sanction operations actions Role Status Create draft sanction operation ENCODER Start=>DRAFT Send draft sanction operation to validator ENCODER DRAFT => TO BE VALIDATED Cancel sanction operation ENCODER DRAFT => CANCELLED Validate sanction operation VALIDATOR TO BE VALIDATED => VALID Send back sanction operation VALIDATOR TO BE VALIDATED => DRAFT Invalidate sanction operation PUBLISHER VALID => INVALID Revalidate sanction operation PUBLISHER INVALID => VALID Confirm invalid PUBLISHER INVALID => CONFIRMED INVALID Prepare to post PUBLISHER VALID => TO BE POSTED Post information PUBLISHER TO BE POSTED => POSTED 66

67 On some of the actions listed above, the system also sends an to the corresponding person in charge (ENCODER, VALIDATOR, and PUBLISHER) for information. Some actions can also be viewed in the Notifications menu. Please find below the list of s sent by the system: When a sanction operation is set invalid, an is sent to all Validators and Publishers. When the validator sends back one or more sanction operations to the encoder, the system sends an to all Encoders for information. At validation, when derogation occurs, an is sent to the configured recipient(s). Information about recipient(s) addresses are stored in FSD configuration parameters. Mail notifications are sent after a successful posting operation. Information about recipient(s) addresses are stored in FSD configuration parameters. When the system detects (at configured time intervals) that some sanctioned entities must be purged, the system sends an to inform configured recipient(s) about sanctioned entities that are going to be erased. When sanctioned entities have been purged, the system sends an to inform configured recipient(s) about sanctioned entities that have been erased. 67

68 7 Workflow Any sanction operation must undergo an approval process from the DRAFT, to TO BE VALIDATED and VALID status. Please find below the different workflow actions. 7.1 Send sanction operation to validation (ENCODER) Once the ENCODER has introduced a sanction operation he must send its DRAFT version for approval to the VALIDATOR. To do this, the user must: search for the last version of the sanction operations via the On-going tab of the Search sanction operations menu / Active Workflow menu (Manage DRAFT tab) select it and click on the Send to validation button. A Send to validation window opens and the user may add a message to be sent to the VALIDATOR, if an is configured to be sent (by default it is not). The comment, if any, is added in the body sent to the user to which the transaction is sent. Confirm the action by clicking on Yes. To abandon the action, answer No: Then click on the Save button. Once done, the status of the selected sanction operations changes from DRAFT into TO BE VALIDATED. The operations will appear in the VALIDATOR s Active Workflow menu (Manage TO VALIDATE tab) or in the Ongoing tab of Search sanctions operations menu. 7.2 Validate sanction operation (VALIDATOR) Once a sanction operation arrives in the VALIDATOR s On-going tab / Active Workflow list, this one can give his approval. This will change the status of the sanction operation into VALID, only if the linked legal base is VALID too. VALID sanction operations appear afterwards in the Prepare to post menu of the Post information menu. 68

69 The VALIDATOR can access to the sanction operation via the Search sanction operations menu- Ongoing tab / Active Workflow menu (Manage TO VALIDATE tab). The system displays a list of all sanction operations that are in TO BE VALIDATED status, together with the login of the ENCODER who sent them to validation: If corrections are necessary to be made by ENCODER, the VALIDATOR can send the sanction operation back to this former for modification, by using the Back to Encoder button (see chapter 7.3). The validator selects a sanction operation or several (by clicking on the Select all button), checks the correctness of information encoded in FSD IS and enters needed corrections, if any is needed, by clicking the the Edit button. If the same user performs the two actions (ENCODER & VALIDATOR), a derogation reason (justification) must be introduced among the following 4 options: Illness, Holidays, Urgency or Other. By default, the system sets Holidays as derogation reason. An additional comment can be introduced, to detail the justification: To validate the sanction click onthe Validate button and confirm the action: 69

70 The status of the sanction operation is now VALID and it will appear in the Prepare to post menu of the Post information menu. Validation is an irreversible action! After validation you can no longer cancel the sanction operation, but you can invalidate it, so that the sanction operation will be excluded from posting operations. 7.3 Send back for correction (VALIDATOR) Where necessary, the VALIDATOR can send back sanction operations which are in status TO BE VALIDATED to the ENCODER for correction or cancellation. To do this, select the sanction operation from the list and clicks on the Back to Encoder button: A Back to encoder window is opened, where the user can enter a comment. The comment, if any, is added in the body sent to the user to which the transaction is sent. Click on the Save button: 70

71 Confirm the action: The system changes the status of the sanction operation from TO BE VALIDATED to DRAFT and the sanction appears now in the Ongoing operation tab of the Search sanctions operations menu or in the Active Workflow menu (Manage DRAFT tab), in DRAFT status. 7.4 Cancel sanction operation (ENCODER) ENCODERS can cancel sanction operations in DRAFT status only (which were not sent to be validated). The sanctioned entity is cancelled too within the same action. The ENCODER selects a sanction operation via the On-going tab of the Search sanction operations menu/ Active Workflow menu. To cancel a sanction, click on the Cancel sanction operation button: 71

72 Confirm the action: The system changes the status of the sanction operations from DRAFT to CANCELLED. This status must be considered as if its sanction operation never existed in the system. 7.5 Invalidate sanction operation (PUBLISHER) Sanctions in VALID status appear in the Prepare to post menu, for the posting. Sanctions may be invalidated for reasons such as a mistake noticed at the very last minute. In such a case invalidation is necessary, to exclude the sanctions from the list of sanctions to be posted! The already VALID sanction operations, can still be invalidated by the user having a PUBLISHER role. The user will always be able to re-validate the sanction operation until a confirmation of invalidation is given. Access the On-going tab of the Search sanction operations menu/ Active Workflow menu (Manage VALID tab). Select one or more sanctions of the result list and click on the Invalidate button: 72

73 A pop-up opens. Enter a comment, if required. The comment, if any, is added in the body sent to the user to which the transaction is sent. Click on the Save button: Confirm the action: The system changes the status of the sanction operation from VALID to INVALID: 73

74 7.6 Manage invalid sanction operations: CONFIRM INVALID/RE- VALIDATE (PUBLISHER) Once a sanction operation is invalidated, 2 further actions are possible: re-validating the sanctions or confirming the invalidation. These can be done by the user having a PUBLISHER role. The workflow is completely finalised only if the PUBLISHER confirms the invalidation. After this confirmation, a new sanction operation may be created on that sanctioned entity, starting from its last posted sanction operation and associated entity version in the track Confirm invalid The PUBLISHER can access the INVALID sanction operation via the On-goin operations tab of the 'Search sanction operations menu/ Active Workflow menu (Manage INVALID tab). Once you select one or several sanctions in INVALID status, 2 buttons are active: Revalidate and Confirm invalid. If the sanctioned entity is no longer to be processed (corrected and revalidated and finally be posted), it must be confirmed invalid. Select the sanctioned entity and click on Confirm invalid : 74

75 Enter a comment, if required, then press the Save button. A confirmation message is displayed: The system changes the status of the sanction operation from INVALID to CONFIRMED INVALID Re-valid invalid sanction operations INVALID sanction operations can still be re-validated, provided they have not been confirmed invalid by the PUBLISHER. 75

76 PUBLISHER selects the sanction operation and clicks on the Revalidate button: The user optionally enters a comment. He clicks on the Save button: A confirmation message is displayed: The system changes the status of the sanction operation from INVALID to VALID. 76

77 8 Active Workflow The Active workflow menu displays sanction operations belonging to all tracks by status, allowing the user to advance in the workflow actions described in the previous chapter. For further details concerning the different actions, please consult the previous chapter 7 Workflow. This menu has the same functionality as the operational search Ongoing operation, with the difference that here there is no need to select the associated working legal base (track). Then all existing on-going sanction operations are listed for all tracks/programmes. Therefore, here you can view and handle together sanctioned entities belonging to different tracks, provided they have the same status (for instance, DRAFT). The menu contains 5 tabs, allowing managing sanction operations in different statuses: DRAFT, TO VALIDATE, VALID, INVALID and ALL. All the users that have some roles can view the sanctioned entities, but the action buttons are only visible for the users who have the proper permissions. The sanctioned entities are displayed in a table containing the following headers: Sanction operation: its type, status and date of the last update Sanction entity: logical ID, name/aliases, status, and version The Working legal base: its number/title and programme User: the user who performed the last modification. To advance in the workflow, in each tab you can select one or several sanction operations to handle them in one go, by clicking on the Select all button. An additional button, Export, allows you to export sanction operations in Excel format: To sort and filter information, please consult the Search results: information management chapter. 77

78 8.1 Manage DRAFT This tab displays sanction operations in DRAFT status. It allows the ENCODER to change their status in TO BE VALIDATED. Three buttons are available and they are activated once the sanction operation is selected. Edit : modify the sanction operation and related entities header and details 'Cancel': it cancels the sanction operation Send to validation : send the sanction for approval to VALIDATOR. 8.2 Manage to validate This tab displays sanction operations in TO BE VALIDATED status. It allows modifying, sending them back or validating them. At this stage the VALIDATOR checks the sanction/entities details against the published legal base, and asks for corrections, if necessary. 78

79 The following 3 actions buttons are available and they are activates once you select the sanction operation: Edit : modify or not the sanction operations entities details Validate : validates sanction operation Back to ENCODER : sends back sanction operations to ENCODER for correction. If the VALIDATOR is the same as the ENCODER who sent the operation for validation, a derogation reason must be entered: 8.3 Manage valid This tab displays sanction operations in VALID status. It allows invalidating sanction operations. 79

80 Two action buttons are available: Edit button: modify the sanction operations/entities header & details Invalidate : invalidate sanction operation. 8.4 Manage invalid This tab displays sanction operations in INVALID status. It allows confirming invalid sanction operations or re-validating them. Two action buttons are available: Revalidate : renders sanction operation in VALID status. Confirm invalid : confirms INVALID sanction operations which were invalidated. 8.5 Manage all This tab displays sanction operations in all statuses. Depending on the status of the selected sanction operation(s), certain action buttons are activated or not. 80

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82 9 Post information (PUBLISHER) The publication process of the sanction operations comprises 2 steps: the preparation to post and the posting operation. These actions can be done by the user with PUBLISHER permissions. 9.1 Prepare to post The PUBLISHER can prepare the publication of all sanction operations in VALID status. Preparing consist in selecting, based on certain criteria VALID sanctions operations whose information will be posted to economic operators and general public on the EEAS website and on the ftp server. Operations that are not in VALID status are not displayed in the list. Legal bases associated to VALID sanction operations are perforce in VALID status. The user may optionally view the details of one selected entity. This can be done via the Prepare to post menu: In the grid all sanction operations in VALID status are displayed in a table with the following headers: Sanctioned entity: logical ID, names/aliases, type and status Sanction operation: type, status, creation date Legal base: programme, name/title. A Select all button allows you to select all sanctions, to be able to handle them in one go. 82

83 You can view details of each entity by clicking on the small arrow in front of the logical ID of the sanction operation and further on, of each entity detail: The user selects the operations to be posted and clicks on the Add to posting operation button. A green confirmation message is displayed in the upper part of the screen and after this operation, the status of the sanction operation changes from VALID into TO BE POSTED. Sanction operations and associated entity versions in TO BE POSTED status may no longer be modified! 9.2 Post information Through the posting process: 1. The sanction operations are further on published in the form of consolidated and delta lists on the web site in order to make them available for all interested stakeholders, public and economic operators. 2. This information is also made available to the economic operators on an ftp server. DG BUDG will have to connect to the FTP server to take the generated files. 83

84 The sanction operations in TO BE POSTED and 'To Be Posted (correction)' statuses can be posted. When clicking on the Post information sub-menu, the list of sanction operations in TO BE POSTED and 'To Be Posted (correction)' statuses is displayed in a table with the following headers: Sanctioned entity: logical ID, names/aliases, type and status Sanction operation: type, status, creation date Legal base: programme, name/title. A Select all button allows you to select all sanctions, to be able to handle them in one go. Four action buttons are available. They are activated once you select one or several sanction operations: Preview XML : allows you to preview the consolidated xml list which will be accessible to external actors: Back to valid : allows user to exclude from the list of the sanctions operations to be published. Their status will change from TO BE POSTED into VALID. 'Abandon corrections': see chapter 10. Post all : allows posting the sanction operations. 84

85 To post information, there is no need to select any rows. It is sufficient that the user clicks on the Post all information button. A pop-up is displayed allowing the user to enter a comment for the posting operation: A final confirmation message is displayed: When answering yes, a posting operation identification number is automatically created: Important! The posting ID is very important, as if any failure during the posting process, this number should be communicated to the support team! After the posting operation: the status of these sanction operation will change to POSTED and the status of the entity will change: a. from INITIALIZED to ACTIVE in case of a new entity b. from ACTIVE to INACTIVE in case of a delisting sanction operation, if in all tracks there are only sanction operations of type Delisting referring to the sanctioned entity. 85

86 Moreover, the sanctioned entity Delisting Date is set to the current system date. The period before purge date starts to be counted from this date. After posting a sanction operation, the system also makes available the created files: on the ftp server, specified in FSD parameters, available to external actors dedicated web site which is accessible to the public (EEAS). The system sends s to economic actors, using the accounts configured in the system. 9.3 Posting history (ADMIN, PUBLISHER) This menu allows the ADMINISTRATOR or the PUBLISHER to search for a post operation that was previously started. It: provides details of system activities to post information to external actors. allows viewing posted xml consolidated and delta files. The system displays the following information about posting operations, in a table with the following headers, that you can further on filter or sort by clicking on the small arrow located next to each criterion: Posting date and time Number of re-launch (if any) Posting ID User who launched the posting operation Comment Result: which can be Ongoing (the process is not finalised), Success or Failure. 86

87 Once the posting successful, 3 action buttons allows the user to perform the following actions on one or several sanctions: Re-launch posting: The re-launch action is available for sanction operations for which posting was not successful (Failure message is displayed in the Result header above). In such a case, the user should contact the application support (see 13). The support should investigate the issue and take an action to allow the user to re-launch the failed posting. View details: allows viewing posting details. This opens a popup containing the list of the sanction entities version that were part of the posting operation. Export: exports the list of posted operations in an Excel file. 4 extra buttons allows downloading the posting information in several formats: ECTL DTD: this file is the consolidated file as generated by ECTL. Delta file: this file is the delta file as generated by ECTL. FSD XSD: this file is a new format that contains all the information about the entities in a proper structure format. CSV: this file is a comma-separated format of all the entities details. 87

88 10 Corrections of posted sanction operations (INFORMATION QUALITY MANAGER) For the cases where the FPI user posted wrong sanctioned entity details or sanction operations of an incorrect type or on the wrong sanctioned entity, the information must be corrected and the correction must be made available to external actors (bank federations). This can be done through a Wrongly posted activity on sanction operations already published (in a POSTED status), by the FPI user with Information Quality Manager permissions. Please note that this type of correction shall be made only for the encoding errors made by the FPI user! It may be the case if, in a previous POSTED sanction operation, the FPI user: 1. chose the wrong sanction operation type or an operation that should have been applied to a different sanctioned entity 2. chose the wrong legal base in same legal bases track 3. chose the wrong legal base in different legal bases track or 4. entered wrong changes in sanctioned entity details Search for the POST sanctions operations to be corrected To do a corrective actions, the user with Information quality manager permission searches in the application the posted sanction operations that present an incorrect sanction operation type and/or an incorrect set of entity information details. He does this by executing a search via the Search sanctions operations menu and introducing the legal base track references for the sanction operation in question. The sanction operation to be corrected is selected, and the user clicks on the small arrow next to the logical ID of the sanction entity, to view its details. Next, the user clicks on the History button to view the versions of the sanction operation (the INACTIVE and ACTIVE ones): 88

89 The user selects the version of the sanction entity that was erroneously posted to the external actors, this is not especially the last version. If the version that is selected is not the last one, all the next version will be considered as erroneously posted as well. He then clicks on the Wrongly posted button, as in the example below: A comment window is displayed, for entering the ground for the correction. The user enters the ground and clicks on the Save button: A confirmation message is displayed: click on Yes to confirm, or on No to abandon the action: The status of the selected sanction operation and of all subsequent ones in the version history of the sanctioned entity in the track changes into TO BE POSTED (CORRECTION). The corresponding entity version status is changed to WRONGLY POSTED: 89

90 The system automatically detects the equivalent type of sanction operation that would re-establish the correct information after posting over the interface towards external actors (for ex. a Creation after an incorrect Delisting). Nevertheless, the system does not create a new sanction operation nor a new version of the sanctioned entity that would display the needed actions over the interface, as it would do for normal operations. Also, in the history of sanctioned entity versions, there is no sanction operation and no associated version corresponding to the posting operation. The user understands that a posting was done by looking at the status of adjacent sanction operations and associated versions. The sanction operation and entities are directly displayed in the Post information menu in the TO BE POSTED (Correction) status. It should be handled like a normal posting activity. For further details, please consult the chapter 9.2 Post information. Subsequently, after having posted the correct information to external actors, the user will be able to create another sanction operation, as needed, to update the latest information of the sanctioned entity, by mean of the usual operational use cases. 90

91 In the public remarks of the selected sanction operation in status "TO BE POSTED (CORRECTION)" that will be posted to external actors the system will automatically add the mention of the last correct sanction operation information, its posting date, and the associated legal base number/title. Before proceeding to the posting, the system gives you several warning messages: 91

92 11 Notifications Whenever certain actions are done in the system (creating draft information, validating information, posting information, etc.), an notification is e sent to the concerned users (having a role in the FSD application workflow). Also, all these notifications are displayed under this menu: Click on the arrow on the left of a notification in order to view its details: The details displayed vary according to the notification type and item concerned, and may include the date and name of the user performing the action. If there is a legal base linked to the concerned item, its details may also displayed. The buttons on the right hand of the page allow the following actions: Expand all click this button to expand the details of all the notifications Collapse all click this button to collapse (hide) the details of all the notifications Erase all click this button to delete all the notifications displayed in the application. Note that clicking this button will not delete the s in your inbox concerning the same actions. 92

93 12 Manage business specific data (ADMIN) 12.1 Tasks The administrator is a Business Administrator who manages a set of data which are used across all operations used during the workflow within FSD. Business specific data are 'types' or specification of common information, like a country or a program. This information is to be managed in the Business specific data menu: Programmes manages codes, names and remarks of the programmes within which the financial sanctions are established. Subject types defines types of subjects for financial sanctions (natural persons, legal persons..etc.) Legal base types defines types of legal base within which are published information about persons subjected to the financial sanctions Organization types defines organization types Countries defines country attribution Identification types defines types of document that identify physical persons or companies. Please find below the business definition and explanation for the data to be entered by the ADMIN in the Business specific data menu: Type Code Definition DEVCO source Justification Programme Set of codes identifying groups of legal bases, often being This business information is for grouping legal bases that apply sanctions on persons, groups, entities or organizational bodies FPI It is the base for organizing the handling of legal bases in FSD 93

94 Type Code Definition DEVCO source Justification the name country under a common legal ground Subject type Natural person, group of persons, enterprises, organizations This type identifies the subject of sanction, principally based on physical person or enterprise. It must follow the EC regulation definition that is published on the OJ EC Regulation published on the OJ referring to sanctioned entities. It is a main attribute of a sanctioned entity used for its identification Legal type base Regulation, amendment, judgment The type of legal base that is managed in FSD OJ and FPI It is a main business object managed by FSD in association to sanctioned entity versions Organization type UN, EC Council, The organization that is the source of the legal base FPI Country Country attribute associated to sanctioned entity address of residence, birth information, nationality and citizenship (linked to identification types). Regulation Country information is associated to sanctioned entity address of residence, birth information, nationality and citizenship (linked to identification types). Identification type ID card, passport, commercial register, VAT, fiscal code, Type of identification document Regulation Used to identify the sanctioned entity 12.2 Manage information The user with ADMIN permissions can record new information on the items described above or can update / delete / disable / enable existing items. The already existing items were migrated from the old ECTL application. 94

95 To manage information, click on the the Business Specific Data menu from the left-hand navigation menu in the application: When accessing one of the sub-menus, the screen is displayed into two zones: The left part consists of the list of existing records (programmes, subject types etc). The ADMIN can select one of them, edit, disable or enable information and below he has a button allowing new entries ( create ); The other part of the window displays the details of the item (name, description). Three actions buttons are available, as in the screen below: Disable, Edit and Delete Create new item The ADMIN can create a new programme by clicking on the Create programme button: Select the type of item you want to create from the left navigation menu (programme, subject type etc). Click on the Create button. A window appears allowing to introduce the mandatory information: Name and Description in the case of the example below (new programme). Click on the Save button to register the new entry, or on Cancel to abandon the action: 95

96 A green confirmation message notifies the user that the change was successful: Edit an existing item For modifying information on an existing item, the ADMIN selects an item from the list (existing programmes in the example below) and clicks on the Edit button. The user can therefore modify description information (name, description). Click on the Save button to register the changes or on Cancel to abandon the action: 96

97 A green confirmation message notifies the user that the modification was registered: Disable/Enable an existing item It is possible to disable items of business specific data. Disabled data can no longer be used across the operations within the system. Disabling means that it will not be possible to use the respective code across the application, but if needed, enabling it will still be possible. To disable an item, select it from the left drop-down list and click on the Disable button. Answer Yes to finalise the action or No to abandon it. 97

98 A green confirmation message notifies the user that the item was disabled: Disabled items may always be enabled again, in which case the system removes the applied restrictions on its usage. You can always use a disabled program as a search criterion. Disabled information is always visible, for example when a reference is made to them in a grid, as a result of a search, or in a combo box. Following rules apply. Disabling has an impact on future actions in the systems; current operations are not impacted. Once disabled, the item can still be enabled, where needed. To do this, select it from the left dropdown list and click on the Enable button: 98

99 A green confirmation message notifies the user that the item was enabled: Delete an existing item It is possible to delete business data. Only items which have no linked sanction operations can be deleted. In the case for example of a programme with linked sanction operations, deletion is not possible. The item can only be disabled! Deleted business specific data is no longer visible in the system. To delete an item, select it from the left drop-down list and click on the Delete button. Click 'Yes' to confirm the deletion or answer No to abandon it: 99

100 For the rest of the data managed in the Business specific data by the ADMIN role, the handling mechanism is almost the same as for the example described above. 100