General provisions

Financial institutions should identify and assess which areas of their business are particularly vulnerable or exposed to restrictive measures and to circumvention of restrictive measures. On this basis, they should put in place, implement and maintain up-to-date policies, procedures and controls to ensure that they can comply effectively with restrictive measures regimes.

These policies, procedures and controls should be effective and proportionate to the size, nature and complexity of the financial institution, and to its restrictive measures exposure.