The use of clauses in relation to trade, economic or financial sanctions or embargos (“sanctions”) in trade finance-related instruments that are subject to the rules drafted by the ICC Banking Commission (“ICC rules”), stating banks’ intention to comply with sanctions regulations, has become a problematic issue for banks involved in trade finance transactions, including, particularly, irrevocable, independent documentary and standby letters of credit, demand guarantees and counter-guarantees.
Sanctions may restrict a bank’s ability to perform its role under ICC rules. International banks may be confronted with different sanctions regimes imposed in the multiple jurisdictions in which they operate. As a result, those banks may be subject to conflicting regulatory requirements, and consequently be amenable to formulating internal policies to mitigate the resulting legal risks. Some banks have chosen to control these legal risks by use of sanctions clauses.
The purpose of this consolidated Guidance Paper is to highlight certain issues arising from the use of such clauses and recommend best practices in that respect.
These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience.
Necessary cookies are absolutely essential for the website to function properly. This category only includes cookies that ensures basic functionalities and security features of the website. These cookies do not store any personal information.
|cli_user_preference||0||11 months||Stores the user’s consent on the current domain.|
|cookielawinfo-checkbox-analytics||0||11 months||This cookies is set by GDPR Cookie Consent WordPress Plugin. The cookie is used to remember the user consent for the cookies under the category "Analytics".|
|cookielawinfo-checkbox-necessary||0||11 months||This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".|
|cookielawinfo-checkbox-non-necessary||0||11 months||This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Non Necessary".|
|cookielawinfo-checkbox-performance||0||1 year||This cookie is set by GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies under the category 'Performance'.|
|cookielawinfo-checkbox-performance||0||1 year||This cookies is set by GDPR Cookie Consent WordPress Plugin. The cookie is used to remember the user consent for the cookies under the category "Performance".|
|JSESSIONID||1||Used by sites written in JSP. General purpose platform session cookies that are used to maintain users' state across page requests.|
|mobile||0||Session||This is a Microsoft SharePoint cookie for internal use of the application.|
|PHPSESSID||0||Session||This cookie is native to PHP applications. The cookie is used to store and identify a users' unique session ID for the purpose of managing user session on the website. The cookie is a session cookies and is deleted when all the browser windows are closed.|
|SERVERID567||0||15 minutes||Session cookie that expires when the page is closed. The operation of the host requires the presence of this cookie corresponding to a number of "SERVERIDES" servers to ensure the proper loading of the site.|
|WSS_FullScreenMode||0||session||This is a Microsoft SharePoint cookie for internal use of the application to indicate whether a page is shown in full screen mode. This cookie expires when you close your browser.|
The audience measurement services used to generate useful statistics attendance to improve the site.
|_pk_id.nnnnn||0||13 months||Matomo cookies: used to store a few details about the user such as the unique visitor ID.|
|_pk_ref.nnnnn||0||6 months||Matomo cookies: used to store the attribution information, the referrer initially used to visit the website.|
|_pk_ses.nnnnn||0||30 minutes||Matomo cookies: short-lived cookies used to temporarily store data for the visit.|
|matomo_ignore||0||12 months||Matomo cookies: this is set if visitors opt-out of website analytics so we remember your preferences.|
Functionality cookies allow websites to remember the user’s site preferences and choices they make on the site including username, region, and language. This allows the website to provide personalized features like local news stories and weather if you share your location.
|cuvid||0||2 years||This cookie is typically written to the browser upon the first visit to the site from that web browser. If the cookie has been deleted by the browser operator, and the browser subsequently visits the site, a new __cuvid cookie is written with a different visitor unique ID. This cookie is used to determine unique visitors to the site and it is updated with each page view. Additionally, this cookie is provided with a unique ID that the application uses to ensure both the validity and accessibility of the cookie as an extra security measure.|
|cuvon||0||30 minutes||Used to signal the last time a visitor viewed a page.|
|lang||0||Session||This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.|
|pum-(numbrer)||session||1 day||This cookie is deposited by the “popup maker” plugin. These cookies are of the form pum- (number). For each "popup window" that is offered on the site, there is a cookie with a different number. These cookies allow you to manage the repeated display of popups in the browser by not showing this popup again if you have closed it.|
A set of cookies to collect information and report about website usage statistics without personally identifying individual visitors.
|sc_anonymous_id||0||9 years||Soundcloud Cookie. This cookie allows users to embed files or other content onto the website, this function can be limited to specific visitors.|
|uid||0||1 year||This cookie is used to measure the number and behavior of the visitors to the website anonymously. The data includes the number of visits, average duration of the visit on the website, pages visited, etc. for the purpose of better understanding user preferences for targeted advertisments.|
|UIDR||0||1 year||The cookie is used to tracks the users activity across the internet on the browser such as visit timestamp, IP address, and most recently visited webpages. and may the data send to 3rd party for analysis and reporting to help their clients better understand user preferences.|
Any cookies that may not be particularly necessary for the website to function and is used specifically to collect user personal data via analytics, advertisement, targeting, other embedded contents are termed as non-necessary cookies. It is mandatory to procure user consent prior to running these cookies on your website.
|amiandoCRT||1||1 year||Xing-event: pending|
|anonymousToken||1||5 months||Xing-event: pending|
|AWSALB||0||Session||A cookie generated by the Application load AWS ELB (Elastic Load Balancer) - Used for managing sticky sessions across production servers.|
|AWSALBCORS||0||Session||This cookie is managed by AWS and is used for load balancing.|
|bcookie||0||2 years||This cookie is set by linkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page. This is a Microsoft MSN 1st party cookie for sharing the content of the website via social media.|
|bscookie||1||2 years||Used by the social networking service, LinkedIn, for tracking the use of embedded services.|
|f_id||third party||365 days||Feathr retargeting: A 24 character hexadecimal text value stored for the purpose of browser identification across sessions.|
|feathr_session_id||third party||1 hour||Feathr retargeting: A 24 character hexadecimal text value stored for relating a set of web activity with a web session.|
|GPS||0||30 minutes||This cookie is set by Youtube and registers a unique ID for tracking users based on their geographical location.|
|lidc||0||1 day||This cookie is set by LinkedIn, used for routing and to store performed actions on the website.|
|lissc||0||1 year||This cookie used for Sign-in with Linkedin and/or for Linkedin follow feature.|
|org.springframework.web.servlet.i18n.CookieLocaleResolver.LOCALE||1||LocaleResolver implementation that uses a cookie sent back to the user in case of a custom setting, with a fallback to the specified default locale or the request's accept-header locale. This is particularly useful for Xing for stateless applications without user sessions.|
|VISITOR_INFO1_LIVE||1||6 months||This cookie is set by Youtube. Used to track the information of the embedded YouTube videos on a website.|
|YSC||1||Session||This cookies is set by Youtube and is used to track the views of embedded videos.|