The bank’s policy stated that it would not become or remain involved in any transaction involving Iraq. This was broader than required by international sanctions relating to Iraq, but the bank was able to take a risk-based approach towards its compliance with the sanctions. We were satisfied the bank did not have to pay the funds into her account as it followed its sanctions policy
We could find no evidence the bank had misled her about her ability to have funds from Iraq put into her account. However, we considered the letters the bank sent to customers to confirm the opening of foreign currency accounts could have been clearer, and we recommended the bank rewrite these letters to draw attention to the potential impact of its sanctions policy on international payments.
We found the bank acted fairly after receiving the funds. It told Zara it could process the payment once she had provided specific information, and it was not the bank’s fault Zara took three months to obtain this information.
We could not uphold Zara’s complaint, and Zara accepted the bank's offer.Print this page