Blocked Governments - deemed by HSBC to be subject to comprehensive prohibitions. This includes Iran, Syria, North Korea and Venezuela. In addition, for Customer relationships maintained in the US, or for activity involving US accounts, products/services, US origin goods, the US Financial System or US Persons, Cuba is deemed a Blocked Government.
Business Activity - includes operations, suppliers, customers, agents, legal agreements, commercial arrangements, contracts, outstanding receivables and/or collectibles, origin or shipping of goods, interactions/exposure to state owned or controlled entities, investments or dealings in bonds and/or securities.
Connected Parties - includes but is not limited to, key officials, partners, directors, authorised representatives, Sole Authorised Signatory, Authorised Representative, Ultimate Beneficial Owner, Key Controller, executors, settlors, donors, protectors, persons authorised to act on behalf of the Customer, an individual which materially contributes to the Customer’s Source of Wealth, and Power of Attorney.
Customer Group – Multi-national Corporation (MNC) or Mastergroup (MG) which is defined as banking relationships (e.g. the parent and subsidiaries) in more than one jurisdiction.
Entity in Customer Group - for example, any subsidiary, branch, joint venture, holding company, representative office, ticket office, operational office or affiliate.
Government of Afghanistan - includes its agencies, public bodies, ministries, foreign embassies, state-owned or state-controlled entities.
Government of Belarus - The Republic of Belarus, the Government of Belarus including (i)public bodies and agencies subordinate to the President or Belarus, including the Administration of the President of Belarus and the Committee of State Control; (ii) the Council of Ministers of Belarus (“CoM”), each of its members (unless acting in a private capacity), and any public body, agency or state concern subordinate to the CoM; (iii) any Ministry of the Government of Belarus; (iv) any State Committee of Belarus; (v) the National Bank of Belarus; (vi) any local government body of Belarus; (vii)any other public body or agency of the Government of Belarus; and (viii) any entity or body directly or indirectly owned 50% or more by, controlled by or acting on behalf of or at the direction of the Government of Belarus, including but not limited to: (i) Belarusbank; (ii) Belinvestbank; and (iii) Belagromprombank.
Nordstream 2 - is an export gas pipeline that will transport natural gas from Russia to Europe under the Baltic Sea.
Petroleum – Products listed in Annex VII of Council Regulation (EU) 2021/1030 and Schedule 2B of The Republic of Belarus (Sanctions) (EU Exit) Regulation 2019.
Potash - Products listed in Annex VIII of Council Regulation (EU) 2021/1030 and Schedule 2B of The Republic of Belarus (Sanctions) (EU Exit) Regulation 2019.
Presence - includes current residential, registered office, business and correspondence address or principal place of operations.
Tobacco - Goods used for the production or manufacturing of tobacco products listed in Annex VI of Council Regulation (EU) 2021/1030 (includes machinery for preparing or making up of tobacco) and Schedule 2B of The Republic of Belarus (Sanctions) (EU Exit) Regulation 2019.
TurkStream - is an export gas pipeline that transports natural gas from under the Black Sea from Russia to Türkiye and Europe, comprising of two parallel lines.
SSI - includes those entities and their subsidiaries that are targeted under the U.S. and/or EU Sectoral Sanctions. Please refer to OFAC’s Sectoral Sanctions Identifications (SSI) List at https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information, https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/ssi_list.aspx and the EU website - Economic sanctions targeting exchanges with Russia in specific economic sectors section for further information on these Sanctions.
Surveillance Equipment - Equipment, technology or software intended primarily for use in the monitoring or interception of internet or telephone communications listed in Annex IV of Council Regulation (EU) 2021/1030 and Schedule 2A of The Republic of Belarus (Sanctions) (EU Exit) Regulation 2019 and any tangible storage medium on which software or technology listed in Schedule 2A of The Republic of Belarus (Sanctions) (EU Exit) Regulation 2019 is recorded or from which it can be derived.
Surveillance Services – Any service where its purpose or effect is to intercept a communication in the course of its transmission by means of a telecommunication system. This includes services that provide access to and delivery of a subject’s incoming and outgoing telecommunication and call associated data for the purpose of its extraction, decoding, recording, processing, analysis or storing, or any other related activity.
U.S. Person - include i) US citizens and US permanent residents (including green card holders), wherever located; ii) any business or entity organised under US law, its non-US branches and, depending on the sanctions program, its non-US subsidiaries; iii) US branches of non-US businesses; and iv) Any person present in the USA, regardless of nationality.
US State Department CAATSA 231 List - entities identified by the US Department of State to be a part of, or operate for or on behalf of, the defence or intelligence sectors of Russia and named on the US Department of State’s CAATSA Section 231 List Regarding the Defense Sector of the Government of the Russian Federation or the US Department of State’s CAATSA Section 231 List Regarding the Intelligence Sector of the Government of the Russian Federation.
