1. Compliance with Sanction Laws: Adherence to the requirements of applicable sanction laws. 

2. Non-Domestic Sanction Programs: Compliance with non-domestic sanction programs where applicable, such as payments in US Dollars, which are subject to US sanction programs. 

3. Implementation of International Sanctions: The bank ensures adherence to international sanctions imposed by the United Nations, European Union, and other relevant bodies. This includes: 

– Regularly updating internal lists of sanctioned entities and individuals based on information from international bodies. 

– Implementing automated screening processes to identify and flag transactions involving sanctioned entities or individuals. 

– Conducting enhanced due diligence for transactions involving countries or sectors subject to international sanctions.

4. Governance and Accountability: The Head of Financial Crime Risk & Money Laundering Reporting Officer (MLRO) is nominated as the Sanctions Officer and is accountable for activities outlined in the policy. 

5. Sanctions Risk Assessment: Conducting a sanctions risk assessment to evaluate sanctions risk for each division. 

6. Risk Appetite: Products and services are not offered if the sanctions risk is outside the risk appetite.

7.Correspondent Banking Relationships: No establishment of relationships with Shell that maintain relationships with Shell , nor engagement in nested services or payable-through accounts. 

8.Foreign Exchange and International Transfer Services: Generally not providing these services to remittance providers or digital currency exchanges unless appropriate controls are in place and approved by relevant authorities. 

9.Due Diligence: Due diligence is applied over key areas of sanctions risks, including: 

– Customers: Name screening processes against lists of designated persons.

– Payments: Screening requirements for international telegraphic transfers via the SWIFT system. 

– Trade Finance: Application of key policy principles to third-party arrangements. 

– Third Parties: Application of key policy principles to third-party arrangements. – Shareholders: Name screening processes against lists of designated persons.

10. Avoiding Sanction Prohibitions: No engagement in structuring transactions to avoid sanctions prohibitions or restrictions. 

11. Staff Training: Providing staff with appropriate training to support policy principles and requirements. 

12. Reporting Breaches: Reviewing and assessing any breach of a sanctions regime and meeting obligations to report to the appropriate authority timely and in accordance with the law. 

13. Compliance and Disciplinary Action: Any staff member who knowingly or recklessly breaches the Sanctions Policy and associated supporting standards and procedures may be subject to disciplinary action. Necessary steps will be taken to comply with laws requiring reporting to law enforcement agencies and cooperation with any law enforcement agency responsible for investigating or enforcing sanction programs.

At the same time, the Company may use a broader catalog of sanction lists, especially in the case of the application of increased financial security measures or any other need in view of the determination of such a need, applying to the circumstances or established/established risks. The catalog as to sanction lists (also listed above) includes:

1) Canada Sanctions List https://www.international.gc.ca/worldmonde/international_relationsrelations_internationales/sanctions/consolidatedconsolide.aspx?lang=eng 

2) EU Sanctions List – https://www.sanctions-intelligence.com/global-lists/ 

3) World Sanctions – https://www.sanctions-intelligence.com/global-lists/ 

4) EU Country Sanctions – https://www.sanctionsmap.eu/#/main 

5) US BIS Denied Persons List – https://www.bis.doc.gov/index.php/the-denied-persons-list

6) UN Sanctions List – https://www.un.org/securitycouncil/content/un-sc-consolidated-list 

7) Sanctions Targets UK – https://www.gov.uk/government/publications/financialsanctionsconsolidated-list-of-targets/consolidated-list-of-targets 

8) Council Regulation (EU) No. 833/2014 of July 31, 2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine (OJ.EU.L.2014.229.1 as amended), 

9) Council Regulation (EU) No. 269/214 of March 17, 2014 on restrictive measures with regard to actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (OJ.EU.L.2014.78.6 as amended), 

10) Regulation (EC) No. 765/2006 of the European Parliament and of the Council of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and Belarus’ participation in Russia’s aggression against Ukraine (OJ.EU.L.2006.134.1, as amended), 

11) Australian DFAT Sanctions List – https://www.dfat.gov.au/internationalrelations/security/sanctions/consolidated-list 

12) SDN List – https://home.treasury.gov/policy-issues/financialsanctions/speciallydesignated-nationals-and-blocked-persons-list-sdn-human-readablelist 

If a client is disclosed on the above-mentioned lists (in terms of specific restrictive measures), the following are applied: 

(a) the freezing of property values owned, held, controlled directly and indirectly by persons and entities, as well as the benefits derived from such property values, by which is meant the prevention of their transfer, alteration or use, as well as the carrying out of any operation with the participation of such values in any way that may cause a change in their size, value, place, ownership, possession, nature, purpose or any other change that may enable benefits to be derived from them; 

(b) not making property values directly or indirectly available to or for the benefit of persons and entities, which means, in particular, not making payments for goods or services.

The Company may select other lists on an ongoing basis, even if they do not fall within the scope of the procedure (sanctions policy), according to the existing risks and information acquired. The databases of sanction lists are updated by the Company, using a re-search for Client with whom business relations have been established (during their duration). 

If a Client appears on one of such lists, the Company: 

1) does not establish business relations or carry out Transactions, 

2) If the Company is in the course of a Transaction, it shall apply retention, 

3) Applies the restrictive measures listed in the Law,

4) In case the Company has a relationship, it shall then terminate such economic relationship.