Sanctions in relation to Russia

Sanctions are a tool used by national governments and supranational organisations (e.g. the EU, the UN) to influence the behaviour of state and non-state individuals, companies and countries in order to achieve foreign policy objectives. The purpose of sanctions is, as part of other foreign policy measures, to influence the policies or actions of that state or group when such policies or actions are considered a threat to international peace and security.

How does Nordea manage sanctions risk?

Nordea has a responsibility towards its customers, shareholders, regulators and the society to ensure that Nordea does not itself violate applicable sanctions laws and regulations and that Nordea’s products and services are not, knowingly or inadvertently, used in violation of relevant or applicable sanctions laws and regulations.

Nordea is committed to ensuring that it complies with all applicable sanctions laws and regulations. Therefore Nordea applies the EU Sanctions Regime, UN Sanctions Regime and adheres to UK and US Sanctions Regimes on a Group-wide basis. Additionally, Nordea has adopted internal policies to address the totality of financial crime risk stemming from specified geographic areas, including North Korea, Iran, Crimea, Sevastopol and the oblasts of Donetsk, Luhansk, Zaporizhzhia and Kerson.

For additional information, please refer to Nordea’s Sanctions Policy Statement.

What is Nordea’s approach on recent sanctions imposed on Russia?

Following the invasion of Ukraine by Russian forces on 24 February 2022, the European Union, the United States, the United Kingdom and many other countries have introduced sanctions in response.

Nordea complies with applicable EU, US and UK sanctions. The sanctions currently include freezing of assets, restrictions on economic relations with certain regions in Ukraine, restrictions focusing on energy and finance sector, import and export restrictions and overflight bans.

As a consequence of the current sanctions regime and the increasing breadth and complexity of sanctions in force; please note

• Nordea has decided not to conduct any business activities that relate to the regions of Donetsk, Luhansk, Zaporizhzhia and Kherson. A similar policy was already in place with respect to Crimea and Sevastopol; and
• due to the current sanctions regime and the restrictions in force, Nordea has stopped processing of payments to and from Russia and Belarus.

What kind of legal advice regarding sanctions can Nordea provide to its customers?

From a legal perspective, Nordea can only provide information on what its sanctions policies are and how they may apply to a transaction you would like to authorise using Nordea’s platform. Nordea does not offer its customers general legal advice on how sanctions laws apply to them or their activities.