Financial Crime World

Mongolia’s Financial Sanctions List: What You Need to Know

In compliance with United Nations Security Council Resolutions, Mongolia has implemented targeted financial sanctions to prevent terrorism and the proliferation of weapons of mass destruction. These sanctions apply to individuals and entities designated by the UN or Mongolia’s competent authority.

The Four Key Sanctions Regimes

  • Sanctions related to terrorism: UNSC Resolution 1267 (1999) and successor resolutions, as well as UNSC Resolution 1373 (2001)
  • Sanctions related to proliferation of weapons of mass destruction: UNSC Resolution 1718 (2006) and successor resolutions - Non-proliferation - DPRK; UNSC Resolution 2231 (2015) and successor resolutions - Non-proliferation - Iran

Mongolian Sanctions Laws and Obligations

  • All persons in Mongolia are subject to targeted financial sanctions obligations under the Anti-Terrorism Law and the Targeted Financial Sanctions Regulation
  • Reporting entities, including financial institutions and designated non-financial businesses and professions, must implement their obligations under the Law/Regulation and establish an adequate compliance program

Obligations for Reporting Entities

  • Freeze all assets: that are directly or indirectly owned or controlled by a designated person or entity
  • Prohibit provision of assets or financial services: directly or indirectly, wholly or jointly to, or for the benefit of, a designated person or entity
  • Report:
    • Known matches with individuals or entities listed on the Consolidated List
    • Suspected matches with individuals or entities listed on the Consolidated List
    • Any freezing actions taken

Violation of Requirements and Obligations

  • Can result in:
    • Fines under the Law on Infringements
    • Administrative action under the Law on Combating Money Laundering and Terrorism Financing, including:
      • Rectification orders
      • Cancellation of special licenses
      • Cancellation, suspension or movement of high-level management officials

Information for Designated Individuals or Entities

  • Can challenge their listing and request to be delisted
  • Can make an application to the General Intelligence Agency to:
    • Use or deal with frozen assets
    • Get access to assets or financial services
  • Must identify the purpose of making the asset or financial service available (i.e. making rent or mortgage payments) and select the permissible basis for the expense

Key Contacts