What does ‘without delay’ mean?

The FATF defines the phrase ‘without delay’ as, ideally, within a matter of hours of a designation by the UN Security Council or its relevant Sanctions Committee [emphasis is ours].

Under the UN Sanctions Act, the term ‘immediately’ is defined as without delay and not later than 24 hours and all TFS measures under the UN Sanctions Act are required to be taken immediately.  The aim is to prevent the flight or dissipation of funds or other assets which are linked to terrorists, terrorist activities, financing of terrorism or financing of proliferation of weapons of mass destruction.

Notwithstanding any other enactment, the definition of ‘immediately’ has to be read as provided in the UN Sanctions Act.