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2.4.1.1.2 Sanctions and embargoes risk

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In this context, sanctions refer to financial sanctions, which can be defined as restrictions on the free movement of capital and payments.[44] These restrictions are imposed on individuals or entities in an effort to curtail their activities and to exert pressure and influence on them. These restrictive measures include (but are not limited to) financial sanctions, trade sanctions, restrictions on travel or civil aviation restrictions.[45] An embargo is defined as a prohibition on commerce.

The Wolfsberg Group published a guide on sanctions screening.[46] However, there is no explicit regulatory definition of the sanctions and embargoes risk. Therefore, we define the sanctions and embargoes risk as the exposure to legal penalties and reputational loss faced by financial institutions failing to comply with existing sanctions or embargoes.

Non-financial Risk Management in the Financial Industry

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