The Compliance business line mobilised for the implementation of sanctions

It is the largest sanctions programme ever implemented at the global level.

The implementation of sanctions is a performance obligation for financial institutions. Beyond this legal aspect, the Crédit Agricole Group must, at this time, demonstrate its perfect alignment with the public authorities and be exemplary and diligent in the implementation of sanctions. 

This entire Compliance business line has done this, in France and abroad, with a very high level of commitment from the teams.

The Group has market tools (deployed as part of the OFAC programme) to perform two types of checks when new sanctions are announced by the authorities: the identification of third parties subject to international sanctions appearing in the databases of the entities of the Crédit Agricole Group (customers, shareholders, suppliers, etc.); the verification of Financial Messages (mainly SWIFT and SEPA) in order to detect transactions potentially prohibited by International Sanctions and to cancel, reject, freeze associated funds, file a report and/or take any other action necessary in accordance with International Sanctions.
The effectiveness of these systems relies on an update of the lists published by the authorities in a timely manner. The list update system has therefore been adapted with intra-day monitoring and the integration of lists several times a day if necessary. Weekend on-call periods were set up on Saturday 26 February to update the lists and ensure that flows are blocked immediately, and that alerts are generated without delay to implement freezing measures.

The different sanctions decided by the authorities vary in nature: the freezing of assets (against legal persons, natural persons, ships or aircraft), sanctions on the financial markets (prohibition of certain transactions), prohibition of certain transactions, exclusion of seven banks from the Swift system, major restrictions on international trade and financing, embargoes on trade and investment concerning Donestk and Louhansk, bans on imports or exports of goods from or to Russia, etc.
Their operational implementation is highly complicated due to the lack of harmonisation of sanctions among the various states (European Union, United States, UK, Switzerland, etc.), operational challenges and difficulties in understanding the regulations, for example on the definition of deposits or certain securities, etc.
This is why regular contact with the authorities and the marketplace has been established.
Should you have any questions, please do not hesitate to contact your entity's Compliance Officers.