Information about international settlements

Terms and conditions of European payments

• The payment currency is EUR.
• Payments can be made in any amount.
• Fee for European payments made by private and business customers in our Internet Bank or through Swedbank Gateways is 0,38 EUR.
• The correct IBAN of the beneficiary is indicated on the payment.
• The service fee type is shared costs (SHA).
• European payment will be received by beneficiary´s bank on the same business day, if you forward your payment order to the bank until 4 pm.
• The beneficiary's bank is in a member state of the European Union and/or the European Economic Area (or Andorra, French Guyana, Gibraltar, Guadeloupe, Martinique, Reunion, Monaco, San Marino, Switzerlandand Vatican City).
• European payments enable you to send more than just the ordinary payment explanation to the beneficiary – you can also include the originator’s reference number and the identification code of either the originator or the beneficiary.

Member States of the European Union and the European Economic Area
Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom.

Other countries to which EU payments can be made
Andorra, French Guyana, Gibraltar, Guadeloupe, Martinique, Reunion, Monaco, San Marino, Switzerland and Vatican City.

Payments are transfered to the beneficiary's bank on a settlement day. A settlement day is a calendar day that is not a Saturday, Sunday, national or public holiday.

Restrictions in executing and performing international payments

Due to Financial Sanctions, Risk Appetite and policies adopted by Swedbank and terms and conditions of Swedbank's correspondent banks, Swedbank has the right not to execute international payments (incl. crediting of incoming payments) in any currencies related to the EU and U.S. comprehensively sanctioned countries/ regions:

1. Iran;
2. Syria;
3. North Korea;
4. Crimea, Sevastopol.

Swedbank may also hold the customer’s payment in order to investigate whether the international payment is not related to Financial Sanctions and is in line with Swedbank internal decisions and correspondent banks’ risk appetite to/from any country/region where embargoes, other restrictive measures are imposed or to/from other high-risk countries/ regions. The execution of stopped international payments may be delayed and customers may be asked to provide additional information about their transactions as a consequence of such investigation.

The list of countries/ regions inter alia includes (the provided list is not full as Financial Sanctions as well as internal decisions can be imposed/ revoked over the time):

1. Cuba;
2. Iraq;
3. Myanmar (Burma);
4. Libya
5. Sudan and South Sudan
6. Yemen;
7. Somalia;
8. Transnistria region;
9. Lugansk/Donetsk.

In assessing if the international payment is related to above mentioned countries/ regions the Bank will check connections to international sanctions imposed and analyse additionally:

• If the payment is related to a customer located or operating in one of above-mentioned countries. The relation could be direct (e.g. payment is received from the sender with the address in Crimea) or indirect (e.g. payment is received from other country (e.g. Turkey), but goods are sent to Syria);
• If the payment is related to front companies, which helps to avoid direct connection to above-mentioned countries;
• If information provided in payment details could be linked to above-mentioned countries (e.g. person name, vessel, name of city, harbour etc);
• If the payment details lack substantial information to understand the payment purpose.

Additional observations

Swedbank would like to draw your attention to the fact that the term of executing international payments or when it already executed (incl crediting of incoming payments), may be extended or international payments may be blocked or frozen by other banks than Swedbank, which also participate in the execution of payment (correspondent banks, bank of beneficiary or sender). Swedbank will not compensate its clients for any damage resulting from the payment being frozen. Therefore, the Customers should always evaluate potential International Sanctions risks by themselves.

Useful links:

• EU (including UN) sanctions regimes: https://www.sanctionsmap.eu/#/main.
• U.S. OFAC sanctions regimes: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.
• U.S. OFAC search tool: https://sanctionssearch.ofac.treas.gov.

International Bank Account Number

IBAN always starts with the two-digit country code, which is followed by two check digits, a reference to the bank (local code of the bank) and the payee’s domestic account number.

Using IBAN reduces delays and errors in payments, because the bank that sends out the payment can check whether the international bank account number is correct before the payment leaves the bank.

To obtain your international bank account number, please use the IBAN calculator

Please note, if you or your company operates in the field of shipping or is connected to mentioned field, then according to international shipping area regulations it is mandatory to add following information to the field 'details of payment':

• M/V: name of the ship;
• IMO: international maritime organisation number;
• FLAG: flag state;
• OWNERSHIP: name of the owner;
• REGISTRATION: number and the country.

Otherwise, payment might be delayed since the missing details will be inquired from the bank of payer. If the payment is not in accordance with international standards (including the U.S. legal acts) the payment might be frozen in the correspondent bank.

Swedbank would like to draw attention to the fact that both the EU and the U.S. imposed broad (comprehensive) International Sanctions related to Crimea and Sevastopol regions. These sanctions cover restrictions and prohibitions on imports, exports, investments and financing in relation to these regions.

Due to the current situation, internal decisions and the risk policies of the main correspondent banks, Swedbank will not, as a rule, perform international payments (both outgoing and incoming) to these regions or related to these regions (i.e. beneficiary address is indicated in Crimea) in any currencies.

Swedbank would like to draw its clients’ attention to the fact that all payments in US dollars to Gazprombank, VEB, VTB, the Russian Agricultural Bank, the Bank of Moscow and Sberbank, any of their subsidiaries and foreign branches are at high risk of being frozen due to the prohibition on financing the USA has established on these banks.

The risk is high because payments associated with concealed financing are difficult to detect, as a result of which unforeseen misinterpretation and different handling by other banks cannot be ruled out.

For ordinary clients (i.e. not financial institutions) the high risk is associated with payments whose recipient (not the recipient’s bank) is listed above or whose payment explanation refers to financing or is directly or indirectly connected to a particular individual (e.g. an owner or representative) associated with a named subject.

In addition to the banks listed above, USD payments to the Donetsk and Lugansk regions of Ukraine also face a heightened risk of being frozen, since both the USA and the European Union have imposed sanctions on ‘national structures’ and related individuals in these areas.

International Sanctions are restrictive non-military measures put in place in order to preserve the international peace and security, as well as respect for human rights. They are imposed by United Nations (UN), European Union (EU) or by individual countries (e.g. United States (U.S.)). International sanctions are imposed against entire states, as well as natural and legal persons, who violate the human rights, commit ethnical, territorial conflicts, support terrorism, violate other international norms and principles.

International Sanctions take various forms based on their purpose objective (e.g. to prevent armed conflict, counter terrorism). They can be individual (e.g. travel ban, asset freeze), target goods and services (e.g. arms embargoes or proliferation-related goods, dual-use goods), can be focused on core economic sectors (e.g. oil or financial sectors) or be comprehensive targeting entire country (e.g. North Korea).

Swedbank, as well as all other financial institutions, implements international Financial Sanctions. It has to be pointed out that depending on the countries where the financial institutions operate, the lists of sanctions which the financial institutions follow could slightly differ.

Financial Sanctions implemented by Swedbank:

• UN. All UN member states are obliged to accept and carry out Resolutions passed by UN Security Council.
  • UN Security Council sanctions regimes: https://www.un.org/securitycouncil/sanctions/information.
• EU. These are implemented through EU Council Regulations and have direct effect in all member states.
  • EU sanctions regimes: https://www.sanctionsmap.eu/#/main.
• Bank also implements relevant U.S. Financial Sanctions based on the Swedbank Group Financial Sanctions Policy. U.S. Financial Sanctions are imposed by U.S. President Executive Orders and implemented by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC).
  By following U.S. Financial Sanctions, the Bank is being able to keep and maintain relations with banks in U.S. jurisdiction and provides payments and other products/services in USD currency or related to U.S. persons to its customers.
  • U.S. OFAC sanctions regimes: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.
  • U.S. OFAC search tool: https://sanctionssearch.ofac.treas.gov.

Additionally, Swedbank considers correspondent bank requirements as well as its own risk appetite. Therefore, Swedbank will not engage in any actions that directly or indirectly circumvent the Financial Sanctions prohibitions, correspondent banks and internal decisions.

Below are provided major types of Financial Sanctions implemented within Swedbank:

• Targeted asset freezes. Swedbank has an obligation to freeze funds of EU blocked person and not to allow making funds available to EU Blocked persons. In case of U.S. imposed sanctions Swedbank will reject transaction or will not provide any products/ services related to OFAC SDN List subjects.
• Arms embargoes/ restrictions on dual-use goods and technology for military purposes (Defence sector). Swedbank is obliged not to participate in provision of financial assistance related to mentioned goods or related services.
• Core economic sector sanctions (Financial, Energy sectors). Swedbank will not provide any financial services restricted (e.g. loans, credits, dealings in financial instruments) as well as will not participate in any transactions related to prohibited activities (e.g. restrictions on provision of goods/ services related to oil sector).

It is important to mention that the asset freeze and some sectoral restrictions are also applicable to entities that are owned or controlled, directly or indirectly, by designated persons. Although those entities may not be itself designated and included into sanctions lists the same Financial Sanctions are applicable for them and needed to be implemented by Swedbank.

EU imposed International Sanctions (including implemented UN sanctions) apply within the territory of EU and to all EU persons inside or outside the territory of EU. Thus, both financial institutions and their customers are legally responsible for complying with the EU sanctions and have the obligation to inform the competent authorities on the cases they know or suspect transactions with sanctioned entities.

Each Customer has to assess potential International Sanctions’ risks when involving themselves in business transactions. International Sanctions are generally widely publicised, and Customers, especially operating internationally, have to understand and take action regarding International Sanctions (not only Financial ones) that might be relevant for them. Therefore, Customers have to consider business activities, which could be exposed to International Sanctions and take appropriate risk mitigation steps.

The information provided above is not all-embracing, and Customers are advised to consult competent authorities or should seek independent legal advice in case of any questions related to implementation of International Sanctions.

Military goods cover military technology and equipment which might be used for internal repression or international aggression or contribute to regional instability.

Dual-use good are items, including software and technology, which can be used for both civil and military purposes, and shall include all goods which can be used for both non-explosive uses and assisting in any way in the manufacture of nuclear weapons or other nuclear explosive devices. Usually when arms embargoes/ restrictions on dual-use items are imposed, related technical, financial assistance as well as other services are also prohibited. Although the primary responsibility for the classification of goods and technologies lies with the Customers sending or receiving such items, the prohibition to provide financial assistance is also mandatory for the Bank.

The prohibition on military goods/ dual-use items means that Swedbank cannot participate in any financial transactions, provide business support or any financial support to customers that sell, supply, transfer, mediate or export such goods to restricted countries (e.g. Russian Federation), if they are intended for military purposes, or sell, supply, transfer or export such goods to the certain EU listed entities. Therefore, Swedbank could conduct additional checks on related payments. Thus, the fulfilment of the payment order may be delayed or rejected.

There are items related to Energy sector listed by EU which are restricted to be exported to Russia. U.S. has imposed restrictions on all goods/ non-financial services or technology in support of energy projects. Therefore, Bank must be aware if the Customer has an authorization from authorities in order not to be involved in prohibited transactions.

• EU Common Military List: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015XG0421(05)&from=EN
• EU Dual use controls: http://ec.europa.eu/trade/import-and-export-rules/export-from-eu/dual-use-controls/index_en.htm
• EU Council Regulation related to Russia: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014R0833-20171202