Additional information on payment transactions related to the states subject to sanctions

After the European Union (EU) and its allies imposed large-scale sanctions and restrictive measures on the Russian Federation, the Republic of Belarus and related entities due to Russia’s open military aggression against Ukraine and its people, we encouraged our customers to re-focus on other markets and reduce dependence on the states subject to sanctions. Having warned our customers and assessed the unacceptability of the risks posed by these states, on 1 September 2022 we stopped payments to/from the Russian Federation and the Republic of Belarus, in all currencies.

After stopping payments, we have noticed increasing attempts to make use of companies formed in the EU and third countries as intermediaries for conducting payment transactions or goods deliveries to/from Russia or Belarus. For example, in order to circumvent the international sanctions, goods are sent to Kazakhstan whereas the actual consignee is in Russia, or, while the country of origin of raw materials is United Arab Emirates according to documents, the goods actually originate in Russia. Such attempts is a proof that the sanctions are working and that there is a high demand for the purchase/sale of relevant goods or services in the states subject to sanctions.

We would like to point out, once again, that, in evaluating payment transactions, the Bank does not tolerate transactions that have a direct geographical relation to Russia or Belarus (e. g. the final place of delivery or the primary place of shipment of the goods is in the geographical territory of Russia and/or Belarus) or which involve an entity registered in Russia and/or Belarus (e. g. as a customer/supplier of goods or services). The Bank does not execute such payments in any currency.

Seeking to help our customers to comply with the international sanctions against Russia and Belarus imposed by the EU and is allies, we recommend that our customers intending to conclude new or continue existing transactions should assess whether the transaction has a direct geographic relation to Russia or Belarus and whether the transaction involves an entity registered in Russia and/or Belarus, specifically, by careful checks of:

• business partners;
• counterparties;
• owners, board members and/or beneficiaries of the above persons;
• the entire chain of the goods and/or services supplied and/or received;
• other entities and factors that may be relevant to your economic activities and may involve a certain risk.

In this way, you will avoid consequences related to legal, reputational and financial risks. 

In the process of provision of financial services, the Bank fully complies with the international sanctions according to the procedure and in the scope prescribed by applicable legal acts. Please note that failure to comply with and violation of the sanctions is a serious crime, therefore, we always report any such violations and attempts to circumvent restrictions to competent authorities.