Financial Crime World

Hamilton Reserve Bank Embraces Global Sanctions Compliance

Introduction

Nevis, Saint Kitts and Nevis - Hamilton Reserve Bank (HRB) has implemented a comprehensive Global Sanctions Compliance Program to ensure strict adherence to international sanctions laws.

Program Structure

The program is led by the Bank’s Chief Compliance Officer and Chief Risk Officer and encompasses five key elements:

  • Procedures: Detailed procedures outlining HRB’s approach to sanctions compliance
  • Systems: Screening systems designed to identify and prevent dealings with sanctioned parties
  • Internal Controls: Measures in place to ensure compliance with applicable sanctions laws
  • Designated Person: A designated person responsible for day-to-day implementation of the program
  • Independent Testing: Regular testing and evaluation of the program’s effectiveness

Employee and Business Partner Obligations

All employees, contingent workers, and business partners must comply with sanctions legally applicable to them in the jurisdictions where they operate. This includes:

  • Prohibitions on transactions involving Specially Designated Nationals (SDNs)
  • Opening or maintaining accounts for SDNs
  • Conducting transactions with prohibited persons or entities
  • Facilitating non-compliant transactions

Real-Time Screening

HRB performs real-time screening of customer relationships and transactions against the SDN list and other legally applicable sanctions lists to prevent dealings with sanctioned parties.

Compliance with Economic Sanctions

HRB must comply with economic sanctions administered and enforced by:

  • The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury
  • EU sanctions programs
  • Restrictions imposed by other countries where the Bank operates

Prohibited Activities

The bank is prohibited from engaging in activities that involve:

  • Sanctioned persons or comprehensively sanctioned countries and regions, including:
    • Cuba
    • Belarus
    • Sudan
    • South Sudan
    • Iran
    • Venezuela
    • North Korea
    • Syria
    • Russia
    • Crimea
    • Donetsk People’s Republic (DNR)
    • Luhansk People’s Republic (LNR) regions of Ukraine

Customer Obligations

HRB customers must ensure that none of their investments, services, goods, or trade involving sanctioned persons, countries, or regions are sent to or processed through the bank or are funded or facilitated by financing provided by HRB.

Contact Information

Questions regarding sanctions compliance can be directed to HRB’s customer service team.