On 24 February, Russian troops crossed the border into Ukraine, reporting attacks across the country. Since then, there has been heavy fighting in many places. The invasion is widely condemned internationally. Several countries are providing humanitarian, military and financial aid to Ukraine. Many Western countries have imposed sanctions on Russia. The three main sanction regimes targeting Russia so far are the United States, the European Union and the United Kingdom, but other countries (such as Japan and Australia) have also imposed sanctions.
You are expected to check that you are not doing business with persons or companies on the sanctions lists. If you use Blanco’s Onboarding and Client File, your clients are screened against all relevant sanctions lists. Blanco uses the services of ComplyAdvantage for this. You can find more information about the sanctions against Russia on the ComplyAdvantage website (link: https://complyadvantage.com/insights/sanctions-on-russia-compliance-updates/).
If a hit comes from the screening, you are obliged to freeze the assets and/or economic resources, to prevent the assets and/or economic resources from being made available directly or indirectly and to prevent the prohibited financial services from being provided. Parties under the supervision of the AFM must pass on the “hit” directly to the AFM in accordance with the instructions on the website of the AFM. If the “hit” can also be designated as an unusual transaction within the meaning of the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), the transaction must also be reported to FIU-the Netherlands without delay.