We must all comply with sanctions rules. Further, industry and insurer expectations mean we take a cautious approach when it comes to sanctions. This is all set out in with our Anti-Money Laundering and Policy.
All new matters are checked against the UK, EU, US and UN sanctions lists upon inception and rescreened against newly sanctioned entities from time to time. Sanctioned persons usually control a number of other corporate vehicles and individuals. Control by a sanctioned individual to any extent, makes the other person or entity controlled as well. The firm's policy is that, where we suspect a link to a sanctioned person, we will investigate that link at the earliest opportunity. If, following that investigation, we are satisfied that there is no link to a sanctioned person, you will be cleared to act if you wish. Where appropriate, ongoing monitoring will be conducted too.
Proximity to sanctions is a material risk factor and we do not wish to undertake work that is proximate to sanctioned persons. As a result, we do not act for any person or entity in a UK sanctioned country and any entity established elsewhere, but with material links to a sanctioned country. We will also not agree to receive funds from a sanctioned country.
Where persons have dual nationality, then they will not be from a sanctioned country for our purposes if they can provide a proof of identification and a proof of address from a non-sanctioned country. We may still at time be obliged to turn them away as a client if they may be reasonably considered to be long-term resident in that sanctioned jurisdiction.
also prohibit us form acting in any way in connection with the transfer of dual use or trade sanctioned goods (e.g. piping, batteries, guidance systems etc.) and acting on public markets transactions in contravention of the access to capital markets sanctions. If in doubt, consult the MLRO.
We occasionally offer a sanctions assurance service for clients or counterparties to rely on, that sets out that certain parties to a deal (and where applicable, vessels) are not subject to any financial sanctions handed down by the UK, EU, US or UN regimes. To access this service you should contact the MLRO.