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Ukraine, Russia Sanctions: Standard Chartered restricts transactions with covered areas

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Standard Chartered Group on Thursday said it does not currently undertake any transaction involving the covered regions, following the Ukraine and Russia sanctions.

On February 21, 2022, the US issued an Executive Order (E.O.) targeting the Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine (the “Covered Regions”).

The details of the executive order include, restrictions in relation to finance and investments; restrictions on the importation, exportation and re-exportation of goods, services and technologies to/from the Covered Regions; restrictions on approval, financing, facilitation or guarantee by a US person, wherever located, of transactions by a foreign person where the transaction by that foreign person would be prohibited by the above if performed by a US person or within the US; and certain blocking requirements in relation to the property of certain individual and entities.

In a statement issued to its clients on Tuesday, transactions include any party in the Covered Regions, exports to or imports from the Covered Regions, investments in the Covered Regions; except in very limited circumstances as determined at the Group’s discretion.

The statement noted that on February 22, 2022, the U.K. designated three individuals and five banks. On the same day, the U.S. designated two financial institutions (along with 42 of their subsidiaries), five vessels and three oligarchs. These parties are all now subject to an asset freeze and, as such, are considered to be Sanctioned Parties by the Group.

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The group adopts a policy of not entering into any transaction that either directly or indirectly involves, or is for the benefit of, any Sanctioned Parties, even where this would be legally permitted. Where required, the Group will look to freeze assets in accordance with relevant restrictions.

On February 22, 2022, the group said the U.S. published Russia-related Directive 1A under Executive Order 1402. This extends existing sovereign debt prohibitions to cover participation in the secondary market, for bonds issued after 01 March 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.

The group said it is firmly committed to complying with all applicable economic sanctions laws that are legally binding upon the Group and its businesses. As a global institution providing financial services that cut across multiple jurisdictions and supported by integrated systems, the Group manages sanctions risk comprehensively and applies restrictions imposed by the EU, UK and US globally across all our markets.

This helps protect our clients and franchise from inadvertent, but costly, sanctions violations, in addition to broader financial crime, compliance and reputational risks.

As such, and given the rapid nature of developments in this space, payments involving Russia and any Russian parties may be subject to additional due diligence at this time. This may result in the Group sending additional requests for information in order to validate the permissibility of payments presented to the Group and a delay in the processing of such payments.

The group is committed to keeping abreast of applicable economic sanctions laws and will continue to monitor the situation and update the Group Policy and Standards accordingly.