Will my transaction be impacted by sanctions?

What are sanctions?

Sanctions are foreign policy tools used by governments and international organisations to support national security interests and/or advance foreign policy objectives. The requirements of different sanctions regimes will vary. Those requirements depend on the government or entity administering them, their intended aims, and the individuals, groups, vessels, and entities they target. Measures commonly imposed include the following:

• Financial restrictions
• Asset freezes
• Travel bans
• Targeted arms embargos, and/or
• Import/export bans on certain commodities.

ASB has an Economic and Trade Sanctions Policy in place to ensure ASB’s compliance with sanctions requirements. This Policy includes prohibitions on carrying out transactions or providing services that may violate sanctions. ASB complies with a number of national and international Sanctions authorities including:

• The United Nations
• New Zealand (Ministry of Foreign Affairs and Trade)
• Australia (Department of Foreign Affairs and Trade)
• United States (Office of Foreign Assets Control)
• The European Union
• United Kingdom (Office of Financial Sanctions Implementation)

How could you be affected?

ASB is committed to ensuring it complies with applicable sanctions obligations. To ensure that ASB and its customers meet sanctions requirements, ASB undertakes due diligence on a wide variety of things, including:

• ASB’s customers
• Trade transactions, including use of controlled/dual use goods
• International payments

ASB strives to make all transactions including international money transfers and currency conversion as requested. However, some transactions may not be processed due to international sanctions laws or ASB’s risk appetite. Some transactions may require further due diligence. ASB will let you know if it cannot process your transaction or if it requires further information from you. 

When ASB is completing the required sanctions due diligence, this may result in extended process times for some transactions for its customers. As part of ASB’s due diligence process, customers may need to provide additional information including, but not limited to, purpose of payment, supporting documents, and additionally for businesses, specific information on ownership relating to counterparties or underlying parties.

ASB will not process any transactions prohibited by sanctions laws or its policies. ASB will also not process transactions where ASB is unable to obtain sufficient information confirming that the transaction does not contravene applicable sanctions and/or its policies. Certain countries/territories are subject to comprehensive sanctions and ASB will not facilitate most transactions involving the following countries/territories:

• Cuba
• Iran
• North Korea
• Syria
• Ukraine disputed/occupied regions (Crimea, Sevastopol, Donetsk, Luhansk, Zaporizhzhia and Kherson)

In addition, ASB will not facilitate commercial and trade finance transactions involving Afghanistan, Myanmar, Ukraine, Venezuela, Russia or Belarus. Personal remittances involving these jurisdictions will only be considered following due diligence and approval processes. Even where transactions are allowed, delays to payment processing should be expected.

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

ASB is unable to advise you on how your transactions can be processed in line with applicable domestic and international sanctions. You are encouraged to obtain independent legal advice and discuss your needs with ASB to minimise the risks of interruptions or delays.

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

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