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The Impact Of Uk Based International Banks

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EXECUTIVE SUMMARY
1. This report provides a high-level overview for the risk committee on how UK based International Banks are exposed to risks in relation to international sanctions. It focuses on the banks responsibilities and legal obligations to comply with both UK and international sanctions and outlines the consequences if obligations are not met.
2. This document outlines the legal framework in which UK banks must operate in relation to Sanctions.
3. A risk based approach is outlined for system and controls in place to avoid circumvention of international sanctions.
SANCTIONS BACKGROUND
i. What are sanctions: Sanctions are enforcement measures used by the international community to maintain or restore international peace and security without the use of armed force or international military action. ii. Types of Sanctions: Financial Sanctions can include Asset Freezing (Terrorist Asset Freezing Act 2010), (Govt Legislation, 2010) prohibition of certain investments, and prohibition to providing economic benefits. Trade Sanctions can be applied to stop arms embargoes and trade sanctions can be used to stop legitimate goods being used for military application. Goods such as fertilizer and medical equipment can have a dual purpose and used for warfare and nuclear weapons. Department for International Trade (Dept for International Trade, 2016) has a list of goods that are restricted due to their dual purpose. Enhanced Due Diligence (EDD) is required for anyone using

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