Jordan: Types of Financial Sanctions Implemented by Local Banks

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In a bid to comply with international sanctions programs, Jordanian banks have adopted robust policies aimed at preventing financial transactions with entities listed in UN Security Council resolutions and other international sanctions lists.

Bank of Jordan’s Sanctions Compliance Program

The Bank of Jordan has implemented a comprehensive sanctions compliance program that covers all its members, including foreign branches and affiliated companies. The program is based on a zero-tolerance approach to non-compliance with international sanctions programs imposed by the United Nations, European Union, and US Department of Treasury’s Office of Foreign Assets Control (OFAC).

Refusal to Deal with Sanctioned Entities

According to the bank’s policy, it refuses to deal with any individuals or entities listed in UN Security Council resolutions. The bank also freezes assets of governments, agencies, individuals, or institutions subject to sanctions regulations issued by the UN Security Council.

Prohibited Transactions

Furthermore, the bank prohibits transactions to and from countries subject to sanctions programs, as well as transactions related to specific economic and commercial activities within these countries. It also complies with sanctions issued by OFAC and the European Union.

Effective Implementation of Sanctions Compliance Program

To ensure effective implementation of its sanctions compliance program, the Bank of Jordan has established an independent function within its Compliance Department. This department is responsible for verifying the application of the bank’s compliance program and following up on international updates and amendments.

Automated Systems and Customer Onboarding

The bank has also implemented automated systems that provide real-time database updates of international lists of individuals and entities listed on embargo lists. These systems are integrated with customer onboarding channels to ensure that new clients are not listed on international embargo lists, and they conduct periodic screening processes to detect any pre-existing clients who may have been listed after account opening.

Clear Work Procedures

In addition, the bank has implemented clear work procedures for handling situations where clients become listed on embargo lists, including escalating and reporting processes. It also verifies parties involved in financial transactions before their execution and uses an online safe-watch system that scans all fields of SWIFT messages for any listed individuals or entities.

Continuous Updates and Training

The Bank of Jordan updates its circulars periodically to reflect the names of countries with high risks according to Security Council resolutions and international sanctions programs. The bank also conducts continuous examinations to verify compliance of all employees with the requirements of its international sanctions compliance program, as well as internal audit programs to independently verify the adequacy of its procedures.

Continuous training programs are also provided for employees of all managerial levels, including the bank’s board of directors, to ensure that they are aware of their responsibilities in adhering to the bank’s sanctions compliance program.