Page 6 Clearstream Banking S.A
Clearstream Banking AG
Due Diligence and Sanctions Questionnaire
IV. Sanctions Certificate
Does your institution have:
- Any offices, transactions, investments, activities or planned activities in sanctioned targets
2
or
- Any transactions, investments, activities or planned activities with (or in) any person or entity located
in sanctioned targets or with (or in) any entity owned or controlled by any entity located in
sanctioned targets?
󠄀 Yes
󠄀 No
If yes, please elaborate, including specific types of investments, transactions or activities and % of total
revenues and/or assets that these instruments, transactions or activities represent for your institution in
sanctioned targets:
____________________________________________________________________________________________________
Sanctions certification
1) The customer provides the certifications below as required by the General Terms and Conditions
governing the provision of services and products by CBL/CBF with the express purpose of assuring
CBL/CBF that the customer's actions will not cause the customer, CBL/CBF or CBL/CBF`s agents,
depositories or correspondents to violate financial or international trade regulations.
2) The customer certifies that, regardless of whether it is subject to the jurisdiction of the EU and any
EU member state, in all dealings with CBL/CBF
(3)
, it will comply with EU regulations regarding
economic sanctions, anti-money laundering, anti-corruption as those regulations exist at the time of
a transaction or service, provided that, for securities denominated in U.S. Dollars or issued or sub-
deposited in the U.S.A., with a U.S. person outside the U.S.A. or having a U.S. person as agent (U.S.-
linked securities) or cash transactions likely to be processed by a U.S. financial institution (U.S. cash
transactions), the customer will comply additionally with U.S. regulations.
3) The customer further certifies that it will not knowingly or with reason to know, use or permit the use
of any CBL/CBF
3
account, directly or indirectly, or enter into or sustain any client relation that would
cause CBL/CBF
3
to violate EU regulations, or in the case of U.S.-linked securities or U.S. cash
transactions, U.S. regulations, regarding economic sanctions, anti -money laundering or anti-
corruption.
2
A sanctions target means any party that is a target of U.S., EU, UK or UN sanctions or to your knowledge,
any other sanctions authority relevant to your institution. Sanctions targets include any party identified on
the OFAC list of SDN, OFAC Foreign Sanctions Evaders List, or OFAC Sectorial Sancti ons Identifications
Lists, and any party identified in, or in annex to, a resolution of the EU or the UN sanctions as a targeted
party. U.S. sanctions targets also include any person or entity that is a citizen or resident of Iran(For
guidance relating to the lifting of certain U.S. sanctions pursuant to the Joint Comprehensive Plan of
Action, please refer to the following link:
https://www.treasury.gov/resourcecenter/sanctions/Programs/Documents/implement_guide_jcpoa.pdf ),
Cuba, Syria, Sudan and North Korea.
3
CBF, except for securities held in collective safe custody.
