Sanctions

What are sanctions risk increasing factors?

The bank recommends to take into account sanctions risk increasing factors, as follows: 

  1. economic activity is related to a territory or border area of a territory or state that is a subject of sanctions; 
  2. economic activity is related to a the military industry; sale, manufacture, import or export  of dual-use goods subject to sectoral sanctions, or specialised foreign agencies (military design bureaux, space technology research agencies, etc.); 
  3. economic or personal activities do not meet their declared economic or personal activities or information on the business partner does not conform to their economic or personal activities; 
  4. business relationship with companies having characteristics of a legitimate business which are used to conceal their financial malpractice, including beneficial owners or economic activities (front company), or business relations with inactive companies for longer time period and whose shareholders, directors or other authorized persons are inactive companies as well (shelf companies); 
  5. cooperation with a service provider transporting goods in states and territories subject to sectoral sanctions or in the border zone of such territories or states; 
  6. cooperation with a service provider transporting goods in states and territories subject to sectoral sanctions or in the border zone of such territories or states; 
  7. cooperation with a service provider regarding which the publicly available information indicates that it provides transport services to companies operating in a territory or state subject to sectoral sanctions; 
  8. the carriage of goods involved in the customer’s transactions takes place in a territory or state, or in the border zone of the territories or states subject to sectoral sanctions, on routes that are not precisely traceable in publicly available internet resources; 
  9. the price of the goods or services involved in the transactions essentially differs from the average price level in the market, the type of transport or storage of the goods involved in the transaction, the route, packaging or other characteristics do not correspond to the general practice in the sector; 
  10. the same documents are used to justify several unrelated transactions; 
  11. the documents supporting transactions contain indications of fraud, providing evidence of possible sanctions evasion; 
  12. within the framework of non-cash remittance, funds are transferred or received from states or territories associated with the export of prohibited goods and services subject to sanctions or carried out in the vicinity of such states or territories. 

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