We ensure the adherence of all relevant requirements of financial and economic sanctions as well as of regulatory requirements. We advise our business divisions regarding the implementation and execution of these requirements. An extensive internal guideline (policy) exists for the adherence of financial and economic sanctions. This internal guideline is updated regularly (at least annually) or if required occasion related.
The bank's client portfolio, parties of transactions and international payments daily respectively in real time pass specified reviews in a monitoring tool against current sanctions lists (e.g. of the EU, UN and other). At this, special techniques are used to detect blurs (fuzzy logic) in spellings of names or critical terms in transactions. Names and payments that show similarities with the sanctions lists or reveal suspicious facts are systematically ejected and comprehensively analyzed regarding compliance with the relevant sanctions regulations. Payments are stopped until final clarification. Confirmed hits lead to rejection or freeze of the payments.
Our employees are obliged to participate annually in a web-based training on financial sanctions and embargos. In addition, occasion related and business specific classroom trainings are conducted.