Article 27 Temporary measures for customers subject to UN financial sanctions

This article addresses a specific and time-sensitive record-keeping obligation for obliged entities when dealing with customers who are subject to UN financial sanctions, or who are controlled by, or majority-owned by, sanctioned persons or entities.

It establishes what must be recorded during the gap period between the moment UN financial sanctions are made public and the moment those sanctions are formally applied as targeted financial sanctions within the EU legal framework.

Important points:

• Keep records of all assets managed for the customer, all transactions attempted, and all transactions carried out on their behalf, from the moment UN financial sanctions are made public.
• The obligation applies specifically to customers who are subject to UN financial sanctions, controlled by sanctioned persons, or in which sanctioned persons hold more than 50% proprietary rights or majority interest.
• This article applies strictly during the window between the public announcement of UN financial sanctions and the formal application of the equivalent targeted financial sanctions in the Union.