International sanctions form an essential foreign policy tool that helps maintain or restore peace, international security, democracy, and the rule of law, while following the human rights law and other international laws. Sanctions are imposed by states (such as the US and the UK), international organisations (such as the UN) and supranational bodies (such as the EU). International sanctions are imposed against entire states, as well as natural and legal persons that violate human rights, commit ethnical, territorial conflicts, support terrorism, or violate other international norms and principles.
International sanctions take various forms based on their objective (e.g., to prevent armed conflict, counter terrorism). Types of sanctions include sanctions imposed on individuals (e.g., travel ban, asset freeze), targeted goods and services (e.g., arms embargoes or proliferation-related goods, dual-use goods), core economic sectors (e.g., oil or financial sectors), or an entire country (e.g., North Korea).
- UN. All UN member states are obliged to accept and carry out resolutions passed by the UN Security Council.
- EU. The EU Council establishes sanctions by regulations that have direct effect to all member states.
- Based on the financial sanctions policy of Swedbank Group, Swedbank implements the relevant US and UK financial sanctions.
- By implementing these, the Bank keeps and maintains relations with banks in the US and the UK jurisdiction and provides payments and other products or services in USD/GBP to persons registered in the US/UK and their customers.
Swedbank considers both correspondent bank requirements as well as its own risk appetite. Therefore, Swedbank does not engage in actions that directly or indirectly circumvent the financial sanction prohibitions, correspondent banks, or internal decisions.
Similarly to other financial institutions, Swedbank implements international financial sanctions as stipulated in § 14 of the International Sanctions Act.
The main types of financial sanctions imposed within Swedbank are as follows:
- Targeted asset freeze. Swedbank has an obligation to freeze funds, i.e., not make funds available to persons blocked by the EU. In case of sanctions imposed by the US and the UK, Swedbank rejects transactions or declines products or services to subjects listed in OFAC SDN or OFSI.
- Arms’ embargoes or restrictions on dual-use goods and technology for military purposes (defence sector). Swedbank is obliged not to participate in the provision of financial assistance related to these goods or related services.
- Core economic sector sanctions (financial, energy sector). Swedbank provides neither restricted financial services (e.g., loans, credit, deals with financial instruments), nor does it participate in transactions related to prohibited activities (e.g., restrictions on provision of goods or services related to the oil sector).
It is important to mention that the asset freeze and some sector-specific restrictions also apply to entities that are owned or controlled, directly or indirectly, by designated persons. While those entities may not be designated or included in the sanction lists, the same financial sanctions are applicable to them and need to be implemented by Swedbank.
Considering the international sanctions, Swedbank’s decisions, requirements of correspondent banks, as well as the current geopolitical situation, Swedbank has the obligation and the right not to execute any direct transactions (including cash and non- cash payments, card payments) in any currencies in its customers' accounts if they are directly related to the following countries or regions (hereinafter referred to as the Prohibited Countries):
- Afghanistan
- Crimea
- Cuba
- Iran
- North Korea
- Republic of Belarus
- Russian Federation
- Syria
- The territories of Ukraine's Donetsk, Luhansk, Kherson, and Zaporizhzhia regions not controlled by the Ukrainian government
- Venezuela
Swedbank also considers indirect transactions as unacceptable (including cash and card payments) in its customers' accounts that are connected to the above-mentioned Prohibited Countries.
All transactions identified in customers' accounts that have any direct and/or indirect connection with Prohibited Countries and which may be deemed unacceptable, will be assessed on an individual basis. Examples of situations that considered unacceptable are as follows:
- Transactions with or connected to natural persons residing and/or operating in Prohibit ed Countries.
- Transactions with or connected to legal entities established and/or operating in Prohibited Countries.
- Transactions with underlying export or import of goods or services, funds, or destination are connected to a Prohibited Countries.
- Deposits of cash derived from the income obtained in a Prohibited Country, for example for the sale or rent of property, sold goods and/or services, dividends or funds related to employment in companies and/or organisations established and/or operating in Prohibited Countries.
We would like to draw your attention to the fact that the term of executing payment transaction may be extended or payment may be blocked or frozen by Swedbank or by other banks that participate in the execution of a transaction (correspondent bank, bank of beneficiary or sender). Therefore, customers should always evaluate potential international sanctions risks.
In addition to the above restrictions, access to the Bank’s products and services might be limited (including initiation/performance of the transaction) when servicing a customer that performs the transactions described above.
International sanctions imposed by the EU (including implemented UN sanctions) apply within the EU territory and to all EU persons inside or outside the EU territory. Thus, both financial institutions and their customers are obliged to comply with the EU sanctions.
As a low-risk bank, Swedbank expects its customers to be aware of their business exposure to international sanctions, in order to avoid measures which could negatively affect their activities.
Each customer must assess potential international sanction risks when involving themselves in business transactions. The international sanctions are generally widely publicised, and customers, especially those who operate internationally, must understand and adhere to relevant international sanctions. Therefore, customers must consider business activities that could be exposed to international sanctions, and take appropriate risk mitigation steps as follows:
- Check, which UN, EU, UK or US sanctions, as well as local (e.g., EE) sanctions apply to the particular country.
- Perform due diligence checks on their partners and customers.
- Familiarise yourself with the due diligence checks of your partners and customers.
- When making payment transfers, please assess whether the payment complies with international sanction requirements; make sure you have the documented proof (e.g., cooperation agreement, agreement between the parties participating in goods transportation, invoices, waybills, references of goods, certificates of origin, primary buyer, final beneficiary, etc.), and be ready to provide it to Swedbank.
The information provided above is not comprehensive, and customers are advised to consult with competent authorities or seek independent legal advice in case of questions related to the implementation of international sanctions.
More information on the EU sanctions is available on the following websites:
Ministry of Foreign Affairs: https://vm.ee/en/sanctions-arms-and-export-control/international-sanctions
Financial Intelligence Unit: https://fiu.ee/rahvusvaheline-finantssanktsioon/rahvusvaheline-finantssanktsioon
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