Financial institutions will not knowingly associate themselves with sanctioned entities or jurisdiction, they may however be involved in the business of trade finance, project finance and insurance
Financial sanctions are restrictions put in place by local government or the multilateral organisations that limit the provision of certain financial services or restrict access to financial markets, funds and economic resources to achieve specific foreign policy or national security objective.
A financial institution will not knowingly associate itself with sanctioned entities or jurisdictions. They may, however, be involved in the business of trade finance, project finance and insurance, and not be aware of the associating sanctions risk.
Such products and or services could inadvertently give rise to sanction risk, among others.
An effective CDD program is one way of gathering information to understanding the scope of such exposure.
COMPLYING WITH SANCTION REGULATIONS
All individuals and legal entities who are within or undertake activities within the UK’s or European Union territory must comply with the EU and UK financial sanctions that are in force.
All UK nationals and UK legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force, irrespective of where their activities take place.
Alongside financial sanctions, respective government may impose controls on certain types of trade. As part of this, the export of goods and services for use in nuclear, radio-logical, chemical or biological weapons programs is subject to strict controls.
While many may not directly or knowingly engage in such programs, the product and services they provide or supply (Import and export trade) could facilitate such outcomes.
Proliferators will seek any opportunities to gain access to means, ways and technology illegally, aiding them is an offence under the Anti-Terrorism, Crime and Security Act 2001
Senior management should be sufficiently aware of the firm’s obligations regarding financial sanctions to enable them to discharge their functions effectively.
How we can assist.
At Leifs&Williams, we can enable you a better understand to scope and meet your obligation, by providing you with subject matter advice, and how to action points on the following.
• Governance
• Risk assessment
• Customer screening (against sanction list)
• Matches and escalation
PROLIFERATION
While many may not worry too much about weapons proliferation, there are specific foreign policy objectives, you must be aware of, especially if you are involved in trade or project finance, and insurance.
We can help you identify, navigate, and understand the relevant controls within trade finance, specifically relating to.
• High-risk jurisdiction
• The make-up or elements of your enhanced due diligence program
• Counter-parties
• Relevant regulations
• Measures and risk of transactions related to proliferation.