Komerční banka, a.s. (hereinafter referred to as the Bank) is a financial institutions that must strictly assess individual clients, transactions and business relationships in their business activities in order to exclude the risk of violating international sanctions measures.
The Bank must not directly or indirectly participate in any way in a business relationship or transaction with clients or counterparties that are persons on binding sanctions lists, or in transactions by clients or third parties that could violate financial or trade embargoes.
In relation to executed or contemplated transactions with a possible risk of violation of international sanction, the Bank is obligated and therefore entitled to ask clients to provide additional information or documents. Notwithstanding the request for assistance during the inspection, the Bank is entitled to reject the transaction under review or to proceed directly to the blocking of financial resources if the assets of the sanctioned person are directly or indirectly involved.
In determining the scope of applied sanction measures, the Bank follows the instructions issued by:
1) The Czech sanctioning authority, which is in first line the Government of the Czech Republic
2) United nations security council
3) European union
4) United States of America-Office of Foreign Assets Control-OFAC
5) Other sanction authorities of third countries such as:
Direction générale du Trésor, France or Office of Financial Sanctions Implementation, United Kingdom
6) Based on a risk assessment by the Société Générale financial group.
In addition to the Bank, other domestic or foreign financial institutions (correspondent banks) are usually involved in the processing of foreign trades, which may apply different and stricter rules, controls or directly strictly limit certain trades in the sanction area. The Bank is obliged to fully respect the approach of other participating institutions in the subject area and is not entitled to change or directly circumvent this approach in any way.