They supplied this information, including documents relating to the sale of the family property and the cryptocurrency investments. The bank then told them it could not accept transactions linked to countries, including Iran, that were subject to international sanctions. Leila and Ali complained that the sanctions did not prohibit all payments from Iran, and that the bank had not established that these sanctions prevented it from accepting their payments. The couple asked us to consider their complaint, and the bank agreed to defer formally rejecting the payments until we had looked into their complaint.

Our investigation

The bank had a policy that it would not be involved in any transaction that had a material link to Iran. Banks are under no general obligation to accept all payments into a customer’s account, and banks can create policies as they see fit, including policies that take a risk-based approach that is stricter than that required by law or sanctions. This meant the bank did not need to prove the payments would be in breach of international sanctions. The bank's refusal to accept the payments did not breach any duty or obligation to Leila and Ali, and the terms and conditions of their accounts allowed the bank to decline to accept a payment in certain circumstances – including if the bank reasonably believed a payment was subject to an international sanctions regime.   

Outcome

We did not uphold the couple's complaint, and the bank proceeded to formally reject the payments.