National authorities, economic blocs like the European Union (EU), and multilateral institutions like the United Nations all have the power to impose restrictive measures against countries, organizations, groups, entities, and individuals who infringe internationally-accepted behaviors and norms, or who have committed crimes such as acts of terrorism. These measures are commonly known as embargoes or sanctions.
We have a responsibility to screen, evaluate, and, if required, observe laws and binding requirements related to financial and trade sanctions set by the EU, Bundesbank, Germany’s Federal Office for Economic Affairs and Export Control, and other authorities such as the US Office of Foreign Assets Control (OFAC) and the UK Treasury Department.
Policy and governance
Our Group-wide Embargo Policy, Special Risk Country Policy, and a policy relating to the Office of Foreign Assets Control help us to assess and reduce client risk as part of our on-boarding process and periodically thereafter, as well as risks related to particular transactions, countries, and goods.
The Sanctions and Embargoes department is organized globally, with regional teams in Frankfurt am Main, London, Singapore, and New York. It focuses on training and awareness, and, in 2016, employees undertook sanctions-related trainings and were proactively informed with updates on any changes to sanctions regulations.
In the wake of the Implementation of the Joint Comprehensive Plan of Action (JCPOA) entered into by world powers and Iran at the start of 2016, we cautiously relaxed our stringent policy towards Iran, and we now execute payments on behalf of long-standing clients in Euros, subject to enhanced due diligence.