From: 

Sent: 24 July 2013 09:22
To:

Subject: RE: The Huuslng Bank of trade ts finance

Importance: 

it will depend on thetype of the sanction and restrictions imposed on the particular
country and that specific entity This needsto be dealt with on case by case basis
and we cannot adopt generalised approach

Forthis particular entity (The Housing Bank of trade finance) the sanction as
highlighted by - below, states restriction on export, sale or UK or
us ofany services.

the exponation, reexportation, sale, or supply, directly or indirectly, from the
United States, or by a United States person, wherever located, of any services to
Syria;"

Even if the fees forthe services are paid by HQ of this is based outside
Syria, we should not be providing any services tothis entity in Syria.

Detailed due diligence needs to be carried out before any services are provided to
entitiesthat are in high risk or are likely to be Sanctioned.

- can we please pickthis up separately.

Mam/thanks



Sent' 24 JUN 2013 09 14

 

Subject: FW The Housing Bank of trade {a finance

Good Morning,

BankersAccuity have several clients in the middle east (non-sanctioned] with end-
users in sanctioned countries i.e. BankersAImanac user based in Syria/Sudan,
however subscription signed and paid in GBP by head office i.e. in Lebanon, Jordan,
UAE.

I would like clarification if we can approve the request below? I understand similar
requests were authorixed in 2011-12 whilst Syria was under international sanctions
on the provision no payment be made directly to/from the sanctioned entity.

The subsidiary in questions does not appear on the major sanction lists i.e. OFAC
SDN, UN, EU, HMT.

Can the Legal Counsel please advise the best course of action. Thank you for your
help.

Kind Regards,