Will my foreign exchange transaction be impacted by sanctions?

What are sanctions?
Sanctions are measures used by governments and international organisations to support national security interests and/or advance foreign policy objectives. The requirements of different sanctions regimes will often vary depending on the government or body administering them.

Sanctions measures commonly include:

• Financial restrictions
• Asset freezes

How could you be affected?

We strive to make all foreign exchange transactions including international money transfers and currency conversion as requested, however  some may not be processed due to international sanctions and will require further due diligence.

Completing the required sanctions due diligence may result in extended process times for some transactions for our customers.

Any transactions that are prohibited by sanctions will not be processed by ASB, nor will transactions be processed where ASB is unable to obtain sufficient information to confirm that the transaction does not contravene applicable sanctions. 

We generally do not enter into, or remain involved in, any transaction that directly or indirectly involves the following countries:

• Afghanistan
• Central African Republic
• Congo, Democratic Republic of
• Crimea and Sevastopol
• Cuba
• Eritrea
• Guinea
• Guinea-Bissau
• Iran, Islamic Republic of
• Iraq
• Korea, Democratic People’s Republic of (North)
• Libyan Arab Jamahiriya
• Somalia
• Sudan-North
• Sudan-South
• Syrian Arab Republic
• Yemen

In addition to the above, the below countries will require additional due diligence and may result in the payment being unable to be processed where we cannot obtain sufficient information. 

• Belarus
• Lebanon
• Mali
• Myanmar (Burma)
• Russia
• Ukraine
• Venezuela
• Zimbabwe

From time to time, these countries may also be subject to additional controls:

• Bosnia and Herzegovina
  
• Croatia
• Egypt 
• Macedonia
  
• Montenegro
• Serbia
  
• Slovenia
• Tunisia

International sanctions are often implemented or changed at short notice in reaction to significant world events; acts of terrorism, for example. Please note, the list of countries to which sanctions apply may change without notice. 

To find out more e-mail EnhancedDueDiligence@asb.co.nz.

ASB’s approach

ASB is committed to ensuring we comply with the applicable sanctions regulations. To make sure that our customers and ASB meet sanctions requirements, we undertake due diligence on:

• Our customers.
• Trade transactions.
• International payments.

As part of our due diligence process, customers may need to provide purpose of payment, supporting documents and additionally for businesses, specific information on ownership including counterparties or underlying parties.

The purpose of this due diligence is to ensure that we:

• Properly identify any sanctions risk represented by our customers, transactions and trade deals.
• Avoid our customers and ASB breaching an applicable sanctions regime as a result of conducting business with, for, on behalf of, or in relation to a designated entity.

Other information around payments and sanctions

It’s also worth noting that whilst ASB performs due diligence and passes payments, those payments may still be stopped by one of the subsequent banks in the payment chain. The actions of those banks are outside ASB’s control; they may request additional information, block the payment or even hold the payment. 

Customers should take extra care when dealing with regions subject to sanctions, and whilst there is considerable information relating to sanctions on various external websites, we recommend customers seek professional advice before committing to business relationships in sanctioned countries. 

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