Sanctions Information for Customers

Sanctions information for customers

Sanctions (as defined) are restrictive measures imposed on individuals or entities or countries in an effort to curtail their activities and to exert pressure and influence on them. Sanctions regulations are derived from the foreign and security policies of the United Nations, the European Union, the United Kingdom and the United States, amongst others.

Comprehensive sanctions aim to prevent all transactions with the Sanctioned Country. They generally allow for exemptions for humanitarian and medical purposes under a general license. However, outside of those exemptions, there can be no imports, exports, provision of financing, exchange or distribution of technology, or any other financial or trade activity.

We have a zero tolerance for breaches of Sanctions (as defined) and will not knowingly provide banking services to persons, entities, vessels or countries where the provision of such a service would breach (or has the potential to breach) Sanctions.

Important notes

• Sanctioned Country means a country or territory which is or whose government is subject to comprehensive, country-wide or territory-wide Sanctions including, without limitation, as at the date hereof, Crimea, the so-called Donetsk People’s Republic, the so-called Luhansk’s People’s Republic, Zaporizhzhia and Kherson regions of Ukraine, Cuba (in respect of transactions which have a nexus to the United States), Iran, North Korea and Syria.
• There are comprehensive sanctions in place against each of the Sanctioned Countries and accordingly, it remains outside our risk appetite (and profile) to provide financial services to customers resident, incorporated or otherwise located in the Sanctioned Countries or where we are on notice that customer funds either originate in or are ultimately destined for use in these countries.
• In certain limited circumstances permitted by law, licence and/or exemption, and strictly on an exceptional case-by-case basis requiring our prior approval, we will consider (at our sole discretion) commencing or continuing a customer relationship with a natural or legal person having trade links to a Sanctioned Country strictly subject to all requirements identified as part of our enhanced due diligence process being met. We do however reserve the right to decline any application or transaction which falls outside our risk appetite.
• The extensive sanctions that have been imposed on Russia and Belarus may be disruptive to business, particularly in the context of our ability to process cross-border, electronic payments to certain Russian and Belarusian individuals, entities and financial institutions, and affected customers should proactively engage with their local Relationship Managers.