Sanctions Compliance

Our committed approach to compliance with relevant sanctions legislation (Australian and applicable international sanctions legislation) is informed by recognition that breaches of this legislation may have a significant impact to the CommBank Group, our employees, customers, the community and the financial system.

We are subject to Australian and applicable international sanctions legislation.  We are also prohibited from directly or indirectly facilitating breaches of sanctions by third parties which may include our customers, counterparties and certain persons associated with them.

We identify and manage our sanctions obligations and risks using a risk-based approach in all jurisdictions in which we operate. Key components of our approach include:

• Maintaining a global sanctions policy which addresses prohibitions on transactions or dealings (directly or indirectly) involving:
  • Sanctioned persons and entities or those who act on their behalf.
  • Sanctioned services, activities or goods (including sanctioned exports and imports).
  • Comprehensively sanctioned countries and regions, including customer access to the Group’s banking platforms from these regions.
• We undertake risk assessments to identify and manage our sanctions risks.
• We provide our staff with training on sanctions obligations.
• We conduct due diligence on our customers and relevant third parties.
• We monitor and screen customer and transactional activity.
• We have processes and controls which we will deploy as we deem appropriate to comply with sanctions legislation and/or our internal policy obligations and/or to manage our risk appetite. Measures may include:
  • Freezing or blocking your accounts and domestic and international funds transfers and reporting these to the relevant regulatory bodies.
  • Rejecting and, in some cases, returning transactions.
  • Determining that we may not enter into, or remain involved in, transactions that have any connection to some sectors of the economy in certain jurisdictions including, but not limited to, the energy, defence, aerospace and telecommunication sectors.

Where possible, we will work with customers and stakeholders to manage the impact of changing sanctions requirements. However, as new sanctions can be imposed with little or no notice, we may be required to alter our policy or process at short notice to remain compliant with Australian and international sanctions obligations.

Sanctions regulations are not limited to financial institutions such as CommBank. Our customers must ensure that none of their transactions or personal or commercial activities are in contravention of applicable sanctions regulations and must not knowingly process prohibited activity through CommBank. We will take all appropriate action where customers have been identified as acting in contravention of relevant sanctions regulations.