Sanctions compliance

Economic sanctions are restrictions on business or trade imposed by one or more markets against other markets, individuals or entities for national security or foreign policy reasons. 

They are intended as penalties to condemn actions that go against international standards and laws, and to encourage changes in those actions.  

We comply with European Union (EU), United Kingdom (UK), United Nations (UN) and United States (US) sanctions globally, and applicable sanctions in the jurisdictions in which we operate.

We do not engage in or facilitate activity with specific governments or parties within certain geographies that are targeted under the sanctions programs of the UK, EU, US, or UN. 

We maintain a policy of not entering into or facilitating any business or transaction that either directly or indirectly involves, or is for the benefit of, any sanctioned parties. To ensure consistent and effective risk management, our internal policies may be stricter than local laws.

Sanctions risks are not limited to direct relationships. They can also arise indirectly, such as when a transaction involves intermediaries or third parties who may be acting on behalf of or for the benefit of a sanctioned entity.

For this reason, we apply robust controls and due diligence across our relationships with clients, service providers, and third-party business partners.

We maintain comprehensive systems and controls to manage sanctions risk, including policies and procedures, risk assessments, due diligence, screening of names and transactions, ongoing monitoring, and training and awareness programmes.

Our banking services are easily accessible from anywhere you travel throughout the world, except in certain jurisdictions that are subject to international economic sanctions such as Cuba, Iran, North Korea, Syria, Crimea and Sevastopol.

Oversight of sanctions compliance sits at a Board and senior management level as part of our wider financial crime risk governance.