Description:

Involves transfers through multiple jurisdictions that are 'friendly' to countries subject to sanctions or that do not enforce United Nations sanctions.

Appears in:

• Acquisition Leveraged Finance
• Borrowing Base Facility
• Certificate of Deposit (Broker Acting as Principal)
• Certificate of Deposit (Broker Acting on Behalf of Client)
• Certificate of Deposit (Direct Interaction with Clients)
• Credit Facility
• Crypto Hawala
• Currency Swap
• Deposit
• Deposit (Direct with Client)
• Deposit (via Broker)
• Discounting of Receivables With or Without Recourse
• Documentary Collections (Export)
• Documentary Collections (Import)
• FX Prime Brokerage (Continuous Linked Settlement)
• FX Prime Brokerage (Non-Continuous Linked Settlement)
• FX Spot
• Import Guarantee (Standby Letter of Credit)
• Letter of Credit and Guarantee Syndication
• Leveraged Loan
• Liquidity Support Facility
• Loan Syndication
• Multi-Product Facility
• Overdraft Facility
• Performance Bond
• Revolving Credit Facility (Bilateral Agreement)
• Revolving Credit Facility (Syndicated)
• Standby Facility
• Traditional Hawala

Addressed by:

• Approval to Make 3rd Party Payment: Compliance approval is required for 3rd party payment and monitoring.
• Early Termination Clause: Legally binding agreements relevant to the service include an early termination clause for high-risk clients or sanctions breaches.
• Know Your Business (KYB): Includes taking steps to gain an understanding of a customer's business activities, including the nature of the business to be taken with a bank and the anticipated volume and value of the business.
• Limits on 3rd Party Payments: Restricted capacity to make 3rd party payments.
• SWIFT Confirmation: Requires confirmation via SWIFT that payment will be used solely for agreed purposes pre-release and post-payment
• Transactional Due Diligence (TDD): Conducts a detailed examination of specific transactions identified as being higher risk.
• Transparent Flow of Funds: Maintains a transparent flow of funds.