Reed Business Information statement about alleged sanction breaches by BankersAlmanac
In the course of a claim for unfair and constructive dismissal, two former employees made allegations in 2013 that the BankersAlmanac business owned by Reed Business Information had breached sanctions regulations. The employment tribunal dismissed the complaint. One claimant is appealing that decision.*
Subsequently, there have been media reports alleging 28 sanction breaches by BankersAlmanac involving financial institutions in Egypt, Iran, Iraq, North Korea and Syria.
Concerning the allegations:
- 16 refer to banks on US sanctions lists. However, BankersAlmanac is a UK entity and therefore not subject to US sanctions. These banks were not on UK or EU sanctions lists when services were provided to them.
- No sales were made to the two North Korean financial institutions.
- The sale to the Iraqi Central Bank was in 2011, and was not subject to EU sanctions at that time.
- BankersAlmanac inadvertently made sales of information products containing publicly available information to Bank Melli and Bank Sepah in Iran during 2008 and 2009, which were subject to EU sanctions. Both subscriptions ended in 2009.
- In 2010, subscriptions were sold to Export Development Bank and Bank Saderat, Iranian banks and in 2011 to Commercial Bank of Syria and Central Bank of Syria. These banks were not subject to EU sanctions at that time and after EU sanctions were imposed, these subscriptions were allowed to lapse and no new sales made. No sale of BankersAlmanac was made to Sina Bank. The subscription to Syria International Islamic Bank had already expired when it was placed on the EU sanctions list. The total value of these subscriptions and lapsed subscriptions was less than £50,000.
Two independent internal investigations found no evidence of any deliberate evasion of applicable sanctions laws. At no time has Reed Business Information been under investigation by any regulator, nor any other authority in relation to sanctions violations.
Reed Business Information has robust policies, procedures and training programmes to ensure compliance with the fluctuating sanctions environment. It tracks and responds to applicable legal developments, monitors guidance by international regulators and would fully co-operate if ever contacted by regulators. The company encourages employees to bring forward compliance concerns; provides confidential channels to enable them to do; and takes all such concerns seriously.
Head of Corporate Communications
1-3 Strand, London, WC2N 5JR, United Kingdom
* Update March 2017
The employment tribunal dismissed the complaint and a subsequent appeal.