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Hamilton Reserve Bank Takes Steps to Ensure Global Sanctions Compliance
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Hamilton Reserve Bank (HRB) has implemented a comprehensive Global Sanctions Compliance Program (“GSC Program”) to ensure compliance with international sanctions regulations. The GSC Program is designed to prevent dealings with sanctioned parties and comply with applicable sanctions laws.
Overview of the GSC Program
The program includes procedures, systems, and internal controls to identify and report suspicious transactions, as well as ongoing training for employees. HRB’s Chief Compliance Officer and Chief Risk Officer oversee the GSC Program, which requires all employees, regardless of location, to comply with sanctions legally applicable to them in their jurisdiction or where they do business.
Screening Systems and Processes
HRB has adopted policies and procedures governing its screening systems and processes to prevent dealings with sanctioned parties. The bank performs real-time screening of customer relationships and transactions against sanctions lists published by the European Union and Her Majesty’s Treasury of the United Kingdom, among others.
Understanding 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, as well as other related U.S. laws and regulatory requirements. The European Union also maintains sanctions programs that apply across all member states, and HRB entities operating within the EU must comply.
Countries and Regions Under Sanctions
HRB is currently prohibited from engaging in or facilitating transactions that have any connection to the following comprehensively sanctioned countries and regions:
- 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 Responsibilities
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 funded or otherwise facilitated by financing provided by HRB. The bank will take appropriate action, including potentially blocking or rejecting funds, with respect to transactions that appear to violate applicable sanctions.
Questions?
For any questions regarding HRB’s Global Sanctions Compliance Program or economic sanctions regulations, please contact the bank directly.