Nationwide Sanctions Policy Statement - Payments
Nationwide Building Society is committed to complying with all relevant Sanctions laws, regulations and codes of the European Union, United Kingdom, United Nations and United States (OFAC). Nationwide’s Payments Screening Sanctions Policy defines the minimum standards which Nationwide must comply with, including:
- Ensuring no unlicensed payments are directly or indirectly remitted to or accepted from an individual or entity that is subject to targeted sanction programmes maintained by HM Treasury (OFSI) and OFAC in respect of the European Union, United Kingdom, United Nations and United States sanctions, and any local regimes in which Nationwide operates.
- Prohibiting business activity, including the acceptance and remittance of payments, directly or indirectly, to countries and territories subject to comprehensive sanctions. From August 2021, these countries and territories include the Crimea region of the Ukraine, North Korea and Syria.
- Restricting business activity, including the acceptance and remittance of certain payments, directly or indirectly, to certain countries or entities subject to selective or targeted sanctions programmes. From August 2021, these countries include Belarus, Iran, Russia/Ukraine, Sudan, Venezuela, Zimbabwe and, where there is a US nexus, Cuba. Payments may also be rejected where they fall outside of Nationwide's risk appetite.
- Investigating all customer alerts or transactions that are stopped in Nationwide’s screening systems. While Nationwide seeks to investigate these alerts and transactions in a reasonable timeframe, compliance with applicable sanctions laws or Nationwide’s Sanction Screening and Management Policy, may result in delays to the processing of payments while additional due diligence is conducted, and information obtained on the nature of the underlying transaction or the parties involved.
- Immediately freezing any funds belonging to a confirmed sanctioned individual or entity.
- Timely reporting of payments to sanctioned individuals and entities to HM Treasury in respect of United Kingdom, European Union and United Nations designated persons, and the US Department of the Treasury in respect of OFAC designated persons. This includes any attempts by the customer to evade sanction laws and servicing any supplementary information requests.
Nationwide may agree to process certain transactions, in its sole discretion, such as those otherwise permitted by a licence from an appropriate authority. These payments will be considered on a case-by-case basis and there may also be a requirement to provide more information, particularly where the payment is in US Dollars. The processing of such payments may incur delays, or subsequently be rejected.
Nationwide may, in its sole discretion, decide not to process certain payments, even where they are permitted by applicable sanctions law or regulations, where these payments fall outside of Nationwide’s risk appetite.
Our clearing banks, and other firms in the payment process, will also apply their own policies and processes to inbound and outbound payments. This may delay the payment if they request further information. In some cases, they may also, in their sole discretion, withhold the funds as required to do so under applicable sanctions laws and regulations, and Nationwide accepts no liability for losses incurred on such occasions.