WHAT DOES THE RISK OF SANCTION CIRCUMVENTION MEAN FOR BELGIAN BANKS?

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WHAT DOES THE RISK OF SANCTION CIRCUMVENTION MEAN FOR BELGIAN BANKS?

  • Margarita Coosemans, Marc Hernandosantacana, Andrea Paladini
  • Published: 04 October 2022


The National Bank of Belgium expects all financial institutions with a presence in Belgium to follow the directives set out by the European Union in regard to the latest sanctions packages. In short, Belgian FIs must ensure that they are not facilitating the movement of funds to or from sanctioned individuals or entities. In this article, we will argue that robust AML and transaction monitoring systems are key to avoiding non-compliance and the consequences of enabling sanctions circumvention.