Understanding U.S. sanctions
The world of economic sanctions is complex, highly regulated and above all, fluid.
Convera and all of its affiliates, are committed to complying with all applicable economic and trade sanctions laws and regulations as required in the countries, territories, and jurisdictions in which Convera operates. Convera’s compliance program includes policies, controls, systems and processes which are designed to ensure compliance with sanctions rules and regulations maintained by, among others, the U.S. Office of Foreign Assets Controls (“OFAC”), the European Union (“EU”), the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”), and the Australian Department of Foreign Affairs and Trade (“DFAT”), as well as rules and regulations in various countries where Convera operates.
As a matter of internal policy, Convera limits transactions involving certain jurisdictions and parties where such business may present unacceptable levels of sanctions-related risk.
Convera systematically screens data associated with its clients and their transactions against names identified on sanctions lists, as well as against terms and descriptors associated with certain sanctioned countries, regions, governments, and other parties. Potential matches are stopped and reviewed by trained analysts to determine whether the transaction involves one or more sanctioned parties. Depending on the nature of the applicable sanction, transactions may be either rejected, with funds returned to originator of the transaction, or Convera may be required to freeze and hold funds.
Frozen and rejected transactions are reported to relevant government authorities as required by applicable laws and regulations. In addition, Convera files annual and other periodic reports of frozen assets in its custody. In general, frozen funds cannot be released or refunded without first obtaining a license or other permission from the appropriate government agency. Convera generally notifies its clients when an account or transaction is frozen or rejected and may advise such parties of the relevant regulator or regulators from whom permission must be sought to obtain a release of the funds or other assets.
Economic and trade sanctions programs administered by OFAC, and other government bodies prohibit or restrict transactions to or from (or dealings with) certain countries, their governments, and in certain circumstances, their nationals. As a result of these prohibitions and restrictions, Convera limits its dealings with certain jurisdictions as follows:
Iran, North Korea, Cuba and the Crimea, Luhansk and Donetsk Provinces of Ukraine
Convera does not process payments to, from or involving Iran, North Korea, Cuba and the Crimea, Luhansk and Donetsk provinces of Ukraine. Convera screens all transactions against lists of geographic and other terms that may indicate the involvement of these countries or regions and investigates clients and transactions as necessary to prevent any activity that is not lawful or otherwise consistent with Convera’s policies.
On case-by-case basis and pre-approval of compliance, Convera may process very limited transactions to, from and involving Syria which are authorized by applicable sanctions regulations.
Convera has controls to identify transactions involving Syria, and each such payment is reviewed by compliance to ensure it meets the requirements of applicable regulations.
On a case-by-case basis with the pre-approval of Convera compliance, Convera may process transactions to/from Afghanistan where it determines such transactions involve support of humanitarian activity in Afghanistan, and where the underlying activity is consistent with parameters set forth by the applicable sanctions’ regulatory authority.
On a case-by-case basis with the company’s approval, Convera will process transactions involving Venezuela where it determines such transactions are authorized under the applicable sanctions regulatory authority and consistent with Convera’s company policy. As a matter of company policy, Convera does not process transactions where any financial institution client of Convera is sending a transaction on behalf of another entity (Natural Person or Corporate Body) resident in Venezuela. Additionally, Convera does not process transactions where any client of Convera is sending a trade-related transaction involving, directly or indirectly, the Venezuelan oil, gas and energy sector or ancillary services including but not limited to construction, shipping, transportation, and professional consulting services.
Convera does not process transactions to/from or involving Russia as a matter of company policy.
Convera does not process transactions to/from or involving Belarus as a matter of company policy.
In addition to the above, Convera closely monitors changes in sanctions requirements and can respond quickly when new sanctions rules are adopting impacting particular regions, countries, or individuals.