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In late 2005, in response to Federal Reserve, Congressional, and grassroots pressure initiated by Divest Terror, UBS adopted a uniform, worldwide economic sanctions policy that combines U.S., E.U., U.N. and Swiss measures against countries, regimes, terrorists, narcotics traffickers, and proliferators of weapons of mass destruction. These measures are not applied to just their US subsidiary but collectively and globally to all UBS’s businesses. 

Their new policy tracks economic sanctions imposed by the United States, Switzerland, the EU and the UN and applies them to all their transactions.   As a result, UBS has decided to exit business in Iran, Cuba, Syria, Sudan, North Korea, and Myanmar. (Where permitted by U.S. law, limited business with individuals in those countries that have no affiliation with their governments may be accepted.)

UBS’ Anti-Money Laundering Program

As part of its new business policies UBS operates a comprehensive series of anti-money laundering controls focusing on key risk areas and dedicates substantial resources towards preventing criminals, corrupt officials, and terrorist financiers from using the firm’s services. These compliance initiatives are designed to meet the highest international standards, including those established by the USA PATRIOT Act, the EU 3rd Money Laundering Directive, and the Swiss Money Laundering Ordinance.

UBS highlighted the three primary tenets of this program in their 29 March 2006 testimony before the House International Relations Subcommittee on Oversight and Investigations.

1. Know Your Customer: Knowing our customers and their financial profiles is a critical first step in assessing our relationships with current and potential clients. As such, UBS does not accept business with anonymous accounts, accounts in fictitious names, or shell companies or trusts lacking transparency as to the beneficial owner. As part of our standard process, every effort is made to identify the source of account assets. We have global standards on the establishment of beneficial ownership and dedicated compliance teams focusing on clients connected to countries of higher risks and on Politically Exposed Persons. In short, we go to great lengths to know potential customers before deciding whether or not to do business with them.

2.  Monitoring and Intelligence: We need the best intelligence to assess our current and potential customers. Therefore, UBS has made substantial investments in intelligent technology and human resources to implement our controls. This technology includes sophisticated monitoring tools designed to screen payments to comply with our sanctions policy and to identify suspicious transactions. UBS now employs approximately 1,750 legal and compliance professionals, of which a substantial number are focused primarily on money laundering prevention.

A now retired Divest Terror web ad used against UBS. 

3.  Culture of Compliance: Having the best policies is important, but they can only be truly effective by establishing a culture among our employees to embrace and implement these policies. Our employees in the United States and all over the world, from senior management on down, appreciate the important and unique role that financial institutions must play in the prevention, detection, and reporting of money laundering. We provide regular training of employees and a firm-wide culture that emphasizes compliance with our policies and the law.

Divest Terror welcomes UBS’s new policies and business practices and will we continue our efforts to see that other international financial and banking companies adopt similar measures.

(Please note that the above description is for informational purposes only and should not be taken as an official endorsment of UBS AG or its products and services.)

Center for Security Policy

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