Compliance officers of banks and financial Intermediaries

For general bank account management:

  • Prior to opening a bank account, ensure that all prospective clients, be they individuals, corporations, their subsidiaries or other entities, are vetted against all UN lists of those designated under an asset freeze;
  • In case any prospective client is designated under any sanctions (other than UN), clarify whether UN sanctions could be justified or their imposition might be reasonably expected;
  • With first time clients, exercise full ‘know your client’ verification, taking into account client-furnished documents, data from government and private sector background checking systems, and individual references;
  • Clarify whether a prospective client is acting as an affiliate of another party with sanctions violation intentions, either as a procurement agent, representative of seller, shipper, or other provider of specialized services such as technical procurement adviser, legal counsel, or by providing financial or transportation services;
  • Consider individuals or entities who have been granted or denied export licenses for prohibited WMD and dual-use equipment to any and all destinations as a pertinent signal for increased due diligence before allowing financial services;
  • File suspicious financial activity reports for all transactions involving prohibited and restricted items destined for states under UN embargo;

For auxiliary financial services, including brokering of credit, investment or insurance services, issuance of letters of credits or other transactional financial services, or in support of barter transactions:

  • Insist that clients furnish all required information and documents leading to financial transactions, with adequate detail and accuracy as is customary for the particular industry, project financing or requested services;
  • Maintain vigilant due diligence as part of a heightened risk in relation to all client requests for transactional services involving individuals with appointments to positions in government, military, security, or state-research services. Clarify purpose and validity of underlying trade;
  • Maintain vigilant due diligence as part of a heightened risk in relation to all client requests for transactions and services involving individuals with nationalities of states under UN sanctions. Clarify purpose and validity of underlying trade;
  • Ensure that any financial transaction involving an end-use certificate for military material or proliferation-relevant goods, components, commodities or information is validated and accurately reflects the proposed transaction;
  • Ensure monetary transactions, financial services or the rendering of fiduciary, brokerage, or insurance services on behalf of investors, beneficiaries, payees, or payers located within a state under any UN embargo do not involve embargoed items;
  • Ensure monetary transactions, financial services or the rendering of fiduciary, brokerage, or insurance services on behalf of investors, beneficiaries, payees, or payers located within a state under any UN embargo do not involve dual use equipment or fall under a catch-all provision as defined under UN embargoes;
  • Ensure potentially embargoed equipment is not identified for financial purposes as being shipped to a destination within a state under UN embargo for “evaluation”, “diagnosis”, or “repair”;
  • Verify all information on application documents and seek matching documentation, for example for insurance, or shipping purposes;
  • File suspicious financial activity reports for all transactions involving prohibited and restricted items destined for a state under UN embargo.