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SC Group Sanctions Policy Statement: Crimea & Sevastopol
SC Group Sanctions Policy Statement: Crimea & Sevastopol
Standard Chartered, including its subsidiaries and affiliates (the “Group”), is firmly committed to
complying with all applicable economic sanctions laws that are legally binding upon the Group and
its businesses.
Any breach of sanctions may have a serious impact on our reputation, franchise, regulatory
relationships and could impair the Group’s ability to provide products and services to clients. The
Group has therefore established a sanctions policy that may be more stringent than what is
permitted by law and regulation.
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.
For these purposes, Sanctioned Parties are defined as:
(a) parties that any one or more of the United Kingdom (UK), the European Union (EU), the
United States (US) or the United Nations (UN) has listed as the target or subject of
sanctions; or
(b) parties which are 50% or more owned (individually or in aggregate) by, or otherwise
controlled by, any party described in (a) above; or
(c) parties which have been internally identified as presenting an unacceptable level of
sanctions risk to the Group.
The Group also prohibits and will not facilitate activity with certain governments or parties within
certain geographies that are targeted under the sanctions programs of the UK, EU, US, or UN.
The Group neither maintains a presence in these sanctioned geographies nor is it the target of
these sanctions programs. As these are a direct consequence of international relations, the
Group’s sanctions policy and specific prohibitions change from time to time. Current prohibitions
include the following:
(a) Cuba – The Group does not undertake any transaction that has any US nexus (e.g.
involving USD, US persons, US goods, etc), involving Cuba, any party in Cuba, or the
Government of Cuba and its agencies and instrumentalities wherever located; except in
very limited circumstances where permitted by an applicable US regulation or Office of
Foreign Assets Control (OFAC) licence and approved in strict accordance with the Group’s
policy and standards;
(b) Iran – The Group does not undertake any transaction involving Iran, any party in Iran, or
the Government of Iran and its agencies and instrumentalities wherever located;
(c) North Korea – The Group does not undertake any transaction involving North Korea, any
party in North Korea, or the Government of North Korea and its agencies and
instrumentalities wherever located; except in very limited circumstances where permitted by
an applicable UK, EU, US, and UN regulation or license and approved in strict accordance
with the Group’s policy and standards;
(d) Syria – The Group does not undertake any transaction involving Syria, any party in Syria,
or the Government of Syria and its agencies and instrumentalities wherever located; except
in very limited circumstances where permitted by an applicable UK, EU, US, and UN
regulation or licence and approved in strict accordance with the Group’s policy and
standards;
(e) Crimea & Sevastopol – The Group does not undertake any transaction involving Crimea
and Sevastopol or any party in Crimea and Sevastopol; except in very limited circumstances
(f) Russia – The Group does not undertake any transaction involving:
(g) Venezuela – The Group does not undertake any transaction related to the provision of
financing for and any other dealings involving the Venezuelan military or the Venezuelan
Government, including its property, or entities owned or controlled by the Venezuelan
Government. These prohibitions also extend to all Venezuelan state-owned entities,
including Petróleos de Venezuela S.A. and the Central Bank of Venezuela. The Group may,
however, consider undertaking transactions that have been permitted by an applicable UK,
EU, US, and UN regulation or licence.
The Group may change the prohibitions described here without notice at any time. If you have
any queries in relation to the Group’s policy position in relation to Sanctions, please contact your
Relationship Manager.