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Sanction Questionnaire Form

Sanction Questionnaire form

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Nandu Murali
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68 views

Sanction Questionnaire Form

Sanction Questionnaire form

Uploaded by

Nandu Murali
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Sanctions Assessment Questionnaire

Corporate Legal Entity Assessment

The purpose of this form is to best identify and assess the nature of any subject exposure. Please
answer the questions set out in Section 1 & 2 for the Legal Entity, where answering “YES” requires
more elaboration.

Date: Legal Entity Name:


Customer Group Name: Country of Incorporation:
Line of Business: Branch Location (where applicable):
CIF Number:

TO BE COMPLETED BY THE CLIENT OR RELATIONSHIP MANAGER (RM)

Section 1: Exposure to Sensitive Sanctioned Countries & List Based Sanctioned Regimes
A. To the best of your knowledge, does the
company have any current or planned Yes  No 
business activity1 in the following
countries/regions?

Iran, North Korea, Syria, Cuba, Sudan


(North), or Crimea.

If “Yes”, please provide further details of


the current or planned business activity
(the legal name, ownership, specific
activities and business operations,
strategy, key suppliers and clients based
in the above mentioned countries, how
transactions are carried forward (banks
and currencies involved), and the extent
of Mashreq’s involvement).

B. To the best of your knowledge, does the


company or any of its connected/related Yes  No 
parties2 have a presence in Iran, North
Korea, Syria, Cuba, Sudan (North), or
Crimea, and/or are currently targeted by
sanctions administered by the following
bodies: UN, EU, UKHMT, HKMA, OFAC, or
any other local sanctions?

If “Yes”, please provide further details of


the Sanction connection (the legal name,
ownership, connected/related parties,
applicable regulatory designation and
sanctions regime and restrictions, specific
activities and business operations, strategy,
key suppliers and clients who are targeted

1
Business activity includes operations, suppliers, customers, agents, origin of goods or shipping route and
interactions/exposure to state owned or controlled entities.
2
All natural persons or Entities associated with a Customer or prospective Customer that must be identified under
the AML Policy and related Standards and local Business procedures. Examples include: key officials (e.g. Chief
Executive Officer, Chief Operating Officer, Chief Finance Officer); partners; directors; Authorized Representatives
and those having the right to appoint Authorized Representatives; Authorized Signatories including secondary card
holders; settlors; Controllers, executors, direct or indirect Owners (including any Ultimate Beneficial Owners) and a
holder of a power of attorney.
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Sanctions Assessment Questionnaire

by sanctions, how transactions are carried


forward (banks and currencies involved),
and the extent of Mashreq’s involvement).

C. Does the company have any current or


planned exposure to Russia or Ukraine in Yes  No 
the energy/oil and gas sector, the military or
defense?

If “Yes”, please provide further details of


the current or planned business activity
(the legal name, ownership, specific
activities and business operations, strategy,
key suppliers and clients based in the above
mentioned countries, how transactions are
carried forward (banks and currencies
involved), and the extent of Mashreq’s
involvement).
D. For each of the Iran Syria Cuba North Sudan Crimea
countries, please list Korea (North)
the annual
percentage
contribution derived
from that country
related to the
company’s total
revenues/sales.

% of company’s total
revenues/sales/assets

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Sanctions Assessment Questionnaire

Section 2 : Exposure to Landlocked Countries

A. To the best of your knowledge, does the Yes  No 


company have any current or planned
business activity or are any of their
suppliers/buyers located in the following
countries/regions?

Afghanistan, Turkmenistan, Uzbekistan,


Azerbaijan, Kazakhstan, Tajikistan or
South Sudan

If “Yes”, please provide further details of the


current or planned business activity (the
legal name, ownership, specific activities and
business operations, strategy, key suppliers
and clients based in the above mentioned
countries, how transactions are carried
forward (banks and currencies involved),
and the extent of Mashreq’s involvement).

% of company’s total revenues/sales/assets in landlocked countries

Country Percentage

The Account Holder/Client hereby acknowledges that Mashreq as a global financial institution prescribes
to various international and local anti-money laundering, counter terrorist financing, financial sanctions
and prohibited business activity laws, regulations, policies and requirements. This means that Mashreq
has adopted tighter controls that can limit its business activity. The increased controls have been
adopted across the Group and are not targeted at the Account Holder/Client.

The Account Holder/Client undertakes that under no circumstance shall it route business activity, directly
or indirectly relating to any person or entity (whether or not related to any of them) which is currently
listed on a Sanctions List, through any of its account(s) maintained with Mashreq.

The Account Holder/Client undertakes that under no circumstance, shall Iran, North Korea, Cuba,
Syria, Sudan (North) & (or) Crimea (restricted countries/regions) related business activity,
directly or otherwise, be routed through any of its account(s) maintained with Mashreq. Business activity
includes, but is not limited to:
 Trade and trade related transaction(s), including but not limited to: shipments/trans shipments
(import/export, insurance / re-insurance, etc.) to/from restricted countries/regions,
 payments to/from restricted countries/regions,
 dealings with governments of restricted country/region or financial institutions/persons/entities
determined to be affiliated with or acting on behalf of the governments of restricted
countries/regions.

The Account Holder/Client therefore acknowledges and accepts that Mashreq retains the right to review
the relationship in light of its risk appetite and terminate the relationship (with the Account Holder/Client
and/or any of the Account Holder/Client sister companies/ joint ventures/ affiliates) should any business
activity, directly or otherwise, relating to restricted countries be conducted through any of its Mashreq
Bank account(s).

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Sanctions Assessment Questionnaire

The Account Holder/Client confirms that it is committed to and shall fully comply with all applicable
international sanctions (including EU, HKMA, UAECB, RBI, UKHMT, UN and US) and upon its knowledge
of any breach, potential breach or circumvention attempt it shall immediately notify Mashreq of the
same.

I/We confirm that this Questionnaire has been signed by ________________ (name of the person) who
holds position of ______________________in the company and that all information is correct and true
at the time of responding and is authorized to provide such certifications / undertakings.

Signature:
Name of the
Person:
Designation:
Date:

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