Gulf International Bank (Uk) Limited

Allegations: GIB(UK) WAS INSTRUCTED BY A NON-US CLIENT TO MAKE FIVE PAYMENTS IN US DOLLARS (US$124, 000 IN TOTAL) TO AN ACCOUNT IN TURKEY HELD BY A MULTI-JURISDICTIONAL ENTITY. GIB(UK) WAS NOT AWARE AT THE TIME THESE PAYMENTS WERE MADE THAT THE ENTITY WAS HEADQUARTERED IN IRAN. PAYMENT INSTRUCTIONS GAVE NO INDICATION OF HEADQUARTER DOMICILE AND GIB(UK)'S SANCTION CHECKING PROCESS DID NOT IDENTIFY THE LINK TO IRAN. THE TRANSACTIONS WERE EFFECTED THROUGH GIB(UK)'S CORRESPONDENT BANK, THE LAST OF WHICH WAS BLOCKED IN NOVEMBER 2013. FOLLOWING NOTIFICATION OF THE LINK TO IRAN BY THE CORRESPONDENT BANK, GIB(UK) APPLIED TO OFAC FOR UNBLOCKING OF THE LAST TRANSACTION IN DECEMBER 2013. IN MAY 2014, GIB(UK) SELF-REPORTED THE TRANSACTIONS TO OFAC PURSUANT TO OFAC'S ENFORCEMENT GUIDELINES FOR ECONOMIC SANCTIONS (31 C.F.R. PART 501, APPENDIX A). GIB(UK) UNDERSTANDS THAT ITS SELF-REPORT REMAINS UNDER REVIEW BY OFAC PURSUANT TO THOSE GUIDELINES. Status: Pending Summary: GIB(UK) WAS INSTRUCTED BY A NON-US CLIENT TO MAKE FIVE PAYMENTS IN US DOLLARS (US$124, 000 IN TOTAL) TO AN ACCOUNT IN TURKEY HELD BY A MULTI-JURISDICTIONAL ENTITY. GIB(UK) WAS NOT AWARE AT THE TIME THESE PAYMENTS WERE MADE THAT THE ENTITY WAS HEADQUARTERED IN IRAN. PAYMENT INSTRUCTIONS GAVE NO INDICATION OF HEADQUARTER DOMICILE AND GIB(UK)'S SANCTION CHECKING PROCESS DID NOT IDENTIFY THE LINK TO IRAN. THE TRANSACTIONS WERE EFFECTED THROUGH GIB(UK)'S CORRESPONDENT BANK, THE LAST OF WHICH WAS BLOCKED IN NOVEMBER 2013. FOLLOWING NOTIFICATION OF THE LINK TO IRAN BY THE CORRESPONDENT BANK, GIB(UK) APPLIED TO OFAC FOR UNBLOCKING OF THE LAST TRANSACTION IN DECEMBER 2013. IN MAY 2014, GIB(UK) SELF-REPORTED THE TRANSACTIONS TO OFAC PURSUANT TO OFAC'S ENFORCEMENT GUIDELINES FOR ECONOMIC SANCTIONS (31 C.F.R. PART 501, APPENDIX A). GIB(UK) UNDERSTANDS THAT ITS SELF-REPORT REMAINS UNDER REVIEW BY OFAC PURSUANT TO THOSE GUIDELINES. THERE HAVE BEEN NO FORMAL COMMUNICATIONS WITH OFAC SINCE THE DATE OF GIB(UK)'S LAST ANNUAL UPDATE TO FORM ADV.

Allegations: OUR NON-US CLIENT INSTRUCTED US TO MAKE A PAYMENT TO AN INDIVIDUAL IN AFGHANISTAN AS PART OF THEIR SCHOLARSHIP PROGRAM FOR USD927.50 FOR VALUE 3RD AUGUST. WITHIN THEIR PAYMENT INSTRUCTION WAS INCLUDED AN INTERMEDIARY BANK, CITIBANK AND AN ACCOUNT NUMBER 36313578. WE MADE THE PAYMENT AS INSTRUCTED BY OUR CLIENT VIA OUR CORRESPONDENT BANK ACCOUNT WITH JPMORGAN. SOME TIME LATER JPMORGAN NOTIFIED US THAT THE FUNDS WERE BLOCKED AND REPORTED TO OFAC. IT WAS THEN UNDERSTOOD THAT THE ACCOUNT NUMBER AT CITIBANK THAT WAS QUOTED IN THE PAYMENT INSTRUCTION BELONGS TO TRANSKAPITALBANK, A RUSSIAN BANK WHO ARE SUBJECT TO SANCTIONS. WE WERE SUBSEQUENTLY NOTIFIED THAT THIS PAYMENT HAD BEEN BLOCKED AND REPORTED TO OFAC PURSUANT TO THE RUSSIAN SANCTIONS REGULATIONS. WE HAVE APPLIED TO OFAC FOR A LICENCE TO EFFECT THIS PAYMENT, WHICH IS CURRENTLY PENDING WITH THEM. Status: Pending Summary: OUR NON-US CLIENT INSTRUCTED US TO MAKE A PAYMENT TO AN INDIVIDUAL IN AFGHANISTAN AS PART OF THEIR SCHOLARSHIP PROGRAM FOR USD927.50 FOR VALUE 3RD AUGUST. WITHIN THEIR PAYMENT INSTRUCTION WAS INCLUDED AN INTERMEDIARY BANK, CITIBANK AND AN ACCOUNT NUMBER 36313578. WE MADE THE PAYMENT AS INSTRUCTED BY OUR CLIENT VIA OUR CORRESPONDENT BANK ACCOUNT WITH JPMORGAN. SOME TIME LATER JPMORGAN NOTIFIED US THAT THE FUNDS WERE BLOCKED AND REPORTED TO OFAC. IT WAS THEN UNDERSTOOD THAT THE ACCOUNT NUMBER AT CITIBANK THAT WAS QUOTED IN THE PAYMENT INSTRUCTION BELONGS TO TRANSKAPITALBANK, A RUSSIAN BANK WHO ARE SUBJECT TO SANCTIONS. WE WERE SUBSEQUENTLY NOTIFIED THAT THIS PAYMENT HAD BEEN BLOCKED AND REPORTED TO OFAC PURSUANT TO THE RUSSIAN SANCTIONS REGULATIONS. WE HAVE APPLIED TO OFAC FOR A LICENCE TO EFFECT THIS PAYMENT, WHICH IS CURRENTLY PENDING WITH THEM.

Allegations: A PAYMENT INSTRUCTION WAS RECEIVED FROM OUR NON-US CLIENT TO PAY A SALARY TO AN INDIVIDUAL IN KYRGYZSTAN AT A LOCAL BANK, VALUE USD5638.64. WHEN PROCESSING THIS TRANSACTION WE SELECTED SBERBANK AS THEIR CORRESPONDENT BANK TO EFFECT USD PAYMENTS. WE WERE LATER NOTIFIED BY HSBC, OUR USD CORRESPONDENT BANK THAT THEY HAD FROZEN THE PAYMENT AND REPORTED IT TO OFAC DUE TO THE SANCTIONS BREACH. WE HAVE APPLIED TO OFAC FOR A LICENCE TO EFFECT THIS PAYMENT, WHICH IS CURRENTLY PENDING WITH THEM. Status: Pending Summary: A PAYMENT INSTRUCTION WAS RECEIVED FROM OUR NON-US CLIENT TO PAY A SALARY TO AN INDIVIDUAL IN KYRGYZSTAN AT A LOCAL BANK, VALUE USD5638.64. WHEN PROCESSING THIS TRANSACTION WE SELECTED SBERBANK AS THEIR CORRESPONDENT BANK TO EFFECT USD PAYMENTS. WE WERE LATER NOTIFIED BY HSBC, OUR USD CORRESPONDENT BANK THAT THEY HAD FROZEN THE PAYMENT AND REPORTED IT TO OFAC DUE TO THE SANCTIONS BREACH. WE HAVE APPLIED TO OFAC FOR A LICENCE TO EFFECT THIS PAYMENT, WHICH IS CURRENTLY PENDING WITH THEM.