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1

Introduction

This financial Sanctions Policy sets out the procedures we have developed to comply with financial sanctions requirements made under the UK sanctions regime that apply to our business[ across every Jurisdiction in which we operate].

2

What are financial sanctions?

1. 2.1

   Financial sanctions are non-permanent international restrictions aimed at:

   1. 2.1.1

      encouraging a change in the behaviour of a particular country or regime;

   1. 2.1.2

      applying pressure on particular countries or regimes to comply with certain objectives;

   1. 2.1.3

      preventing and suppressing terrorist financing.

1. 2.2

   Financial sanctions are also used as a last resort enforcement tool when international peace and security has been threatened.

1. 2.3

   Financial sanctions restrict dealings in Money and the provision of financial services—they can include the prohibition of funds transfers to and from certain countries, individuals or entities.

1. 2.4

   They are designed to have an adverse impact on persons (individuals or corporate entities) that are designated or (for some sanctions) connected with a prescribed country, in a number of different ways. These can include freezing their funds or economic resources, and/or preventing:

   1. 2.4.1

      funds or economic resources being made available to them (or for their benefit) or received from them (directly or indirectly);