International Sanctions take various forms based on their purpose objective (e.g. to prevent armed conflict, counter terrorism). They can be individual (e.g. travel ban, asset freeze), target goods and services (e.g. arms embargoes or proliferation-related goods, dual-use goods, luxury goods, etc.), can be focused on core economic sectors (e.g. oil or financial sectors, goods which could contribute in particular to the enhancement of country's industrial capacities) or be comprehensive targeting entire country (e.g. North Korea).
Swedbank implements international and national financial sanctions based on Law on International Sanctions and National Sanctions of the Republic of Latvia. It has to be pointed out that depending on the countries where the financial institutions operate, the lists of sanctions which the financial institutions follow could slightly differ.
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UN. All UN members are obliged to accept and carry out Resolutions passed by UN Security Council.
UN Security Council sanctions regimes: https://www.un.org/securitycouncil/sanctions/information
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EU. These are implemented through EU Council Regulations and have direct effect in all member states.
EU sanctions regimes (there is a search function): https://www.sanctionsmap.eu/#/main
- Based on the Swedbank Policy on Financial Sanctions, Swedbank implements relevant U.S. and UK financial sanctions.
Additionally, Swedbank considers correspondent bank requirements as well as its own internal regulations. Therefore, Swedbank will not engage in any actions that directly or indirectly circumvent the financial sanctions prohibitions, correspondent bank requirements or Swedbank Policy on Financial Sanctions.
Below are provided major types of financial sanctions implemented within Swedbank:
- Targeted asset freeze. Swedbank has an obligation to freeze all financial resources and financial instruments owned, held or controlled by subjects of EU, UN and LV financial sanctions and not to allow making funds available to such persons. In case of U.S. and UK imposed sanctions Swedbank will reject transaction or refrain from provision of any products/ services related.
- Arms embargoes/ restrictions on dual-use goods and technology for military purposes (defence sector). Swedbank is obliged not to participate in provision of financial assistance related to mentioned goods or related services.
- Core economic sector sanctions (financial, energy sectors). Swedbank will not provide any financial services restricted (e.g. loans, credits, dealings in financial instruments) as well as will not participate in any transactions related to prohibited activities (e.g. restrictions on provision, exportation, or reexportation of goods/services or technology in support of exploration or production for deepwater, Arctic offshore, or shale projects that have the potential to produce oil).
It is important to mention that the asset freeze and some sectoral restrictions are also applicable to entities that are owned or controlled, directly or indirectly, by a designated person.
Although those entities may not be designated and included into sanctions lists the same financial sanctions are applicable for them and needed to be implemented by Swedbank.
EU imposed International Sanctions (including implemented UN sanctions) apply within the territory of EU and to all EU persons inside or outside the territory of EU. Thus, both financial institutions and their customers are legally responsible for complying with the EU sanctions and have the obligation to inform the competent authorities on the cases they know or suspect transactions with sanctioned entities.
Each Customer has to assess potential international sanctions’ risks when involving themselves in business transactions. International sanctions are generally widely publicised, and Customers, especially operating internationally, have to understand and take action regarding international sanctions (not only financial sanctions) that might be relevant for them. Therefore, customers have to consider business activities which could be exposed to International Sanctions and take appropriate risk mitigation steps.
The information provided above is not all-embracing, and customers are advised to consult responsible authorities or should seek independent legal advice in case of any questions related to implementation of sanctions.
Swedbank is a low-risk bank; therefore, we have defined and adhere to a low risk appetite, also in managing financial sanction risks. This means that we aim to avoid sanction breaches not only when sanctions target specific transactions but also related activities (e.g., export restrictions).
In view of the international sanctions, the requirements of correspondent banks, the current geopolitical situation, Swedbank has the obligation and the right not to execute any direct transactions (including cash and non-cash payments, card payments) in any currencies in its customers' accounts if they are directly related to the following countries or territories (the “Prohibited Countries”):
- North Korea
- Syria
- Iran
- Russian Federation
- Crimea and Sevastopol
- The territories of Ukraine's Donetsk, Luhansk, Kherson, and Zaporizhzhia regions not controlled by the Ukrainian government
- Republic of Belarus
- Cuba
- Venezuela
- Afghanistan
Swedbank also considers indirect transactions as unacceptable (including cash and card payments) in its customers' accounts that are connected to the above-mentioned Prohibited Countries.
All transactions identified in customers' accounts that have any direct and/or indirect connection with the Prohibited Countries and which may be deemed unacceptable, will be assessed on an individual basis. Examples of situations considered unacceptable include:
- Transactions with or connected to natural persons residing and/or operating in the Prohibited Countries.
- Transactions with or connected to legal entities established and/or operating in the Prohibited Countries.
- Transactions where the underlying export or import of goods or services, funds, or destination are connected to the Prohibited Countries.
- Deposits of cash derived from the income obtained in a Prohibited Country, for example, from the sale or rent of property, sale of goods and/or services, dividends or funds related to employment in companies and/or organisations established and/or operating in the Prohibited Countries.
We would like to draw your attention to the fact that the time of executing payment transaction may be extended or the transaction may be blocked or frozen by Swedbank or by other banks involved in the execution of such a transaction (correspondent bank, payee’s or payer’s bank). Therefore, customers should always evaluate potential risks of international sanctions.
In addition to the above restrictions, access to Swedbank’s products and services may be limited (including initiation/performance of the transaction) when serving a customer that performs the transactions described above.
Useful links:
EU (including UN) sanctions regimes:
https://www.sanctionsmap.eu/#/main
U.S. OFAC sanctions regimes:
https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx
U.S. OFAC search tool:
https://sanctionssearch.ofac.treas.gov/
UK sanctions regimes:
https://www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-lists-and-releases
UK sanctions search tool:
https://sanctionssearchapp.ofsi.hmtreasury.gov.uk/
Swedbank would like to draw attention to the fact that both the EU and the U.S. has imposed broad international sanctions related to Crimea and Sevastopol regions. These sanctions cover restrictions and prohibitions on imports, exports, investments and financing in relation to these regions.
In 2022, multilateral organisations and different countries (such as the U.S.) have imposed trade restrictions and prohibitions in the sectors of transport, telecommunications, energy or the prospecting, exploration and production of oil, gas and mineral resources and import of goods originating in the non-government-controlled areas, such as Donetsk, Kherson, Luhansk and Zaporizhzhia regions.
Due to the current situation and according to the internal policy of the bank and the risk policies of the main correspondent banks, Swedbank will not, as a rule, execute payments, direct or indirect, in any currency to/from or in relation to these regions (i.e. the beneficiary’s address is indicated in any of the regions, as well as in other cases where any connection with these regions has been identified).
In response to Russia's unprecedented and unprovoked military attack on Ukraine, a number of international sanctions have been imposed on the Russian Federation, as well as on the Republic of Belarus.
The current situation has made transactions with Russia and Belarus very risky. Customers who make payments or send goods to Russia run a real risk of losing their money or goods.
That is why Swedbank has suspended direct and indirect payment services to and from Russia and Belarus, except for a few exceptions, such as pension payments. Incoming payments, direct and indirect, will be returned to the originator.
Military goods cover military technology and equipment which may be used for internal repression or international aggression or contribute to regional instability.
Dual-use goods are items, including software and technology, which can be used for both civil and military purposes, and include all goods which can be used for the manufacture of arms and military equipment, weapons of mass destruction or their delivery, etc.
Usually when arms embargoes/ restrictions on dual-use items are imposed, the related technical, financial assistance as well as other services are also prohibited. Although the primary responsibility for the classification of goods and technologies lies with the customers sending or receiving such items, the prohibition to provide financial assistance is also mandatory for the Bank.
The prohibition on military goods/ dual-use items means that Swedbank cannot participate in any financial transactions, provide business support or any financial support to customers that sell, supply, transfer, mediate or export such goods to restricted countries (e.g., the Russian Federation), if they are intended for military purposes, or sell, supply, transfer or export such goods to the certain EU-listed entities. Therefore, Swedbank may conduct additional checks on related payments. As a result, the execution of the payment order may be delayed or cancelled.
There are EU-listed items related to the energy sector listed by the EU which are restricted for export to Russia. The U.S. has imposed restrictions on all goods/ non-financial services or technology in support of energy projects. Therefore, the Swedbank must be aware if the customer has an authorization from competent or sanctions-issuing authorities in order to not be involved in prohibited transactions.
Sectoral sanctions against Russia
In response to the military aggression, the EU has significantly expanded sanctions against Russia, adding unprecedented restrictive measures to the list of sanctions, supplementing the existing measures applied to Russia since 2014 in connection with the annexation of Crimea and the violation of the Minsk agreements. The newly introduced sanctions against Russia include not only an embargo on goods, but also a ban on the provision of services. Goods that may not be exported to Russia are, for example: goods and technology suited for use in aviation or space industry, luxury goods, maritime navigation goods and technology, goods and/or technology suited for use in oil refining, goods which could contribute in particular to the enhancement of the Russian industrial capacities. Goods that may not be imported from Russia include: crude oil and refined petroleum products, coal and other solid fossil fuels, steel, gold including jewellery, cement, wood, paper and plastic, seafood and alcoholic beverages. The EU has prohibited the provision of certain business-related services to the Russian government, or any legal entity established in Russia: accounting services, IT consulting, legal consulting, architectural and engineering services, advertising, market research and public opinion research services. Any EU-registered legal person, entity or body of which 25% or more is owned by a Russian natural or legal person, entity or body is prohibited from becoming a road transport company engaged in the carriage of cargo by road within the territory of the EU, including in transit.
Sectoral sanctions against Belarus
In response to human rights violations in Belarus and the violent repression of civil society, democratic opposition and journalists, the EU has imposed new sanctions against Belarus since 2020.
In light of the falsified results of the presidential elections in Belarus on 9 August 2020 and the violence committed by Belarusian security forces against peaceful protesters, the democratic opposition and journalists, the EU has imposed sanctions against a number of natural and legal persons. On 4 June 2021, the Council also banned all Belarusian airlines from taking off from, landing in or overflying EU territory.
In view of Belarus' involvement in Russia's unprovoked and unjustified war against Ukraine, on 29 June 2024 the EU adopted additional restrictive measures targeting the Belarusian economy. These restrictive measures are aimed at imposing sanctions already in place against Russia, thereby limiting the circumvention of sanctions imposed against Russia as a result of the high degree of integration between the Russian and Belarusian economies. The new sanctions include trade restrictions, a ban on the supply of certain services, transport and logistics restrictions and anti-circumvention measures that will affect various sectors of the Belarusian economy.
Please note that the above lists are not complete. The full list of prohibited goods and services, as well as other restrictions can be found in the link below.
EU Common Military List
EU Dual use controls
EU Council Regulation related to Russia sectoral sanctions
EU Council Regulation related to Belorussian sectoral sanctions
Please note that if you or your company operates in or is connected with the shipping industry or mentioned field, it mandatory under international shipping regulations to add the following information in the “Payment Details” field, when making payment:
- M/V: name of the ship.
- IMO: international maritime organisation number
- FLAG: flag state
- OWNERSHIP: name of the owner
- REGISTRATION: number and the country of registration
Otherwise, the payment may be delayed since the missing details will be requested from the bank of the payer. If the payment is not in accordance with the international standards (including the U.S. legislation), the payment may be frozen in the correspondent bank.
Please note that there are multiple restrictions on shipping sector imposed by the EU, the U.S. and others (e.g., Russian and Belarusian ships are prohibited from docking in EU ports). Therefore, if during the evaluation the Swedbank has identified sanction risks, the transaction may be rejected/returned to sender on the grounds of Swedbank’s internal policy.
Swedbank classifies field of transportation as a high-risk industry by the reason of possible transportation of sanctioned goods (ex. military goods, dual-use goods, goods related to energy sector, etc.) and provision of services which are prohibited by EU, U.S. OFAC, UK or UN legal requirements.
Please note, if you or your company operates in the field of transportation or is connected to mentioned field, then you will be required to provide following information to the Swedbank:
- Information regarding transported goods (including, but not limited to the following: Certificate of origin of goods, bills, invoices, transportation documents (ex. rail, air waybills) etc.)
- Information regarding final destination/final beneficiary of goods (beneficiary name, registration number, country, address)
- Information regarding consignor (beneficiary name, registration number, country, address).
If Swedbank requests you to provide documents and received information will not include all necessary information, payment might be delayed or rejected according to Swedbank Internal policy reason.
Proliferation financing refers to any financial means used to support the proliferation of weapons of mass destruction (WMD) or their acquisition activities. This type of financing can be extremely dangerous as it can contribute to the dissemination of technologies and materials that pose a threat to global security. The Swedbank does not engage in any transactions that may indicate the use of funds to finance proliferation.
