UBS has for many years applied enhanced levels of scrutiny to clients with a link to Myanmar and took the decision to apply additional restrictions on business relationships linked to Myanmar in March 2021, well before the FATF blacklisting in October 2022. 

In March 2021, in response to the military coup in Myanmar and the related social unrest, UBS added the country to the list of jurisdictions subject to “Group Financial Crime Risk Oversight Committee (GFC ROC)” restrictions, effectively restricting any new business for individuals and entities domiciled in Myanmar, or which otherwise have a material source of wealth from Myanmar. All existing relationships for individuals or entities resident in, or substantially connected to Myanmar have been subjected to a dedicated review and any relationships approved for retention are subjected to a higher risk rating which involves an annual review and enhanced levels of monitoring and surveillance. UBS also screens its client base against external sanctions and other watchlists and undertakes ongoing adverse media screening. More specifically, UBS screens all wire transfers against sanctions lists issued by the UN, EU, SECO, OFAC and HMT on a real time basis and screens all of its clients against these lists on a daily basis. In the event a true positive match is identified, this is fully investigated and the relevant action taken vis a vis reporting to sanctions authorities across jurisdictions. 

UBS Group (incl. Credit Suisse) does not have a direct business relationship with any state-owned bank in Myanmar and it adheres to all UN as well as the member state and supranational sanctions regimes referenced above on a global basis.