Solutions for Receiving Bank Transfers from High-risk Countries

of Facts事实摘要Wanzhou Meng (“Meng”), also known as “Cathy Meng” and
“Sabrina Meng,” is the Chief Financial Officer (“CFO”) of Huawei
Technologies Co. Ltd. (Huawei”), a corporation organized under the laws
of the People’s Republic of China (“PRC”) and the world’s largest
telecommunications equipment company. Meng is a citizen of the PRC and a
daughter of Huawei’s founder, Ren Zhengfei. In addition to her role as
CFO, Meng currently serves as Huawei’s Deputy Chairwoman of the Board,
and serves or has served in various roles at other Huawei subsidiaries
and affiliates. Meng also served on the board of Hong Kong-based Skycom
Tech Co. Ltd. (“Skycom”) in or about and between February 2008 and April

FRAUD中国电信集团华为和华为首席财务官孟晚舟被控财务欺诈Huawei Device USA
Inc. and Huawei’s Iranian Subsidiary Skycom Also Named Defendants
Charges Include Money Laundering, Conspiracy to Defraud the United
States, Obstruction of Justice and Sanctions
Violations其他指控包括洗钱、阴谋欺诈美国、妨碍司法和违反制裁A 13-count
indictment was unsealed earlier today in federal court in Brooklyn, New
York, charging four defendants,including Huawei Technologies Co. Ltd.
(Huawei), the world’s largest telecommunications equipment manufacturer,
with headquarters in the People’s Republic of China (PRC) and operations
around the world. The indicted defendants include Huawei and two Huawei
affiliates — Huawei Device USA Inc.(Huawei USA) and Skycom Tech Co. Ltd.
(Skycom) — as well as Huawei’s Chief Financial Officer (CFO) Wanzhou
defendants Huawei and Skycom arecharged with bank fraud and conspiracy
to commit bank fraud, wire fraud and conspiracy to commit wire fraud,
violations of the International Emergency Economic Powers Act (IEEPA)
and conspiracy to violate IEEPA, and conspiracy tocommit money
laundering. Huawei and Huawei USA are charged with conspiracy to
obstruct justice related to the grandjury investigation in the Eastern
District of New York. Meng is charged with bank fraud, wire fraud,and
conspiracies to commit bank and wire
U.S. Attorney General Matthew G.Whitaker, Secretary Kirstjen Nielsen of
the U.S. Department of Homeland Security, Secretary Wilbur Ross of the
U.S. Department of Commerce, U.S. Attorney Richard P. Donoghue for the
Eastern District of New York, FBI Director Christopher A. Wray,
Assistant Attorney General Brian A. Benczkowski of the Justice
Department’s CriminalDivision and Assistant Attorney General John C.
Demers of the National Security Division, announced the
we are announcing that we are bringing criminal charges against
telecommunications giant Huawei and itsassociates for nearly two dozen
alleged crimes,” said Acting Attorney General Whitaker. “As I told
Chinese officials in August, China must hold its citizens and Chinese
companies accountable for complying with the law. I’d like to thank the
many dedicated criminal investigators from several different federal
agencies who contributed to this investigation and the Department of
Justice attorneys who are moving the prosecution efforts forward. They
are helping us uphold the rule of law with
charged in the indictment, Huawei and its Chief Financial Officer broke
U.S. law and have engaged in a fraudulent financial scheme that is
detrimental to the security of the United States,”said Secretary
Nielsen. “They willfully conducted millions of dollars in transactions
that were in direct violation of the Iranian Transactions and Sanctions
Regulations, and such behavior will notbe tolerated. The Department of
Homeland Security is focused on preventing nefarious actors from
accessing ormanipulating our financial system, and we will ensure that
legitimate economic activity is not exploited by our adversaries. I
would like to thank ICE Homeland Security Investigations for their
exceptional work on this
years, Chinese firms have broken our export laws and undermined
sanctions, often using U.S. financial systems to facilitate their
illegal activities,” said Secretary Ross. “This will end. The Trump
Administration continues to betougher on those who violate our export
control laws than any administration inhistory. I commend the Commerce
Department’s Office of Export Enforcement, and our partners in the FBI,
Justice Department, Department of Defense, and Department of Homeland
Security fortheir excellent work on this
charged in the indictment, Huawei and its subsidiaries, with the direct
and personal involvement of their executives,engaged in serious
fraudulent conduct, including conspiracy, bank fraud, wirefraud,
sanctions violations, money laundering and the orchestrated obstruction
of justice,” stated U.S. Attorney Donoghue. “For over a decade, Huawei
employed a strategy of lies and deceit to conduct and grow its business.
This Office will continue to hold accountable companies and their
executives, whether here or abroad, that commit fraud against U.S.
financial institutions and their international counterparts and violate
U.S. laws designed to maintainour national security.” Mr. Donoghue
thanked the FBI, U.S. Immigration and Customs Enforcement’s Homeland
Security Investigations (HSI), U.S. Department of Commerce Office of
Export Enforcement(OEE) and the Defense Criminal Investigative Service
(DCIS) agents who are investigating this case for their tireless work
charges lay bare Huawei’s alleged blatant disregard for the laws of our
country and standard global businesspractices,” said FBI Director Wray.
“Companies like Huawei pose a dual threat to both our economic
andnational security, and the magnitude of these charges make clear just
how seriouslythe FBI takes this threat. Today should serve as a warning
that we will not tolerate businesses that violate our laws,obstruct
justice, or jeopardize national and economic
of the Indictment起诉书概述The charges in this case relate to
along-running scheme by Huawei, its CFO, and other employees to deceive
numerous global financial institutions and the U.S. government regarding
Huawei’s business activities in Iran. As allegedin the indictment,
beginning in 2007, Huawei employees lied about Huawei’s relationship to
a company in Iran called Skycom, falsely asserting it was notan
affiliate of Huawei. The company further claimed that Huawei had only
limited operations in Iran and that Huaweidid not violate U.S. or other
laws or regulations related to Iran. Most significantly, after news
publications in late 2012 and 2013 disclosed that Huawei operated Skycom
as an unofficial affiliate in Iran and that Meng had served on the board
of directors of Skycom,Huawei employees, and in particular Meng,
continued to lie to Huawei’s banking partners about Huawei’s
relationship with Skycom. They falsely claimed that Huawei had sold its
interest in Skycom to an unrelated third party in 2007 and that Skycom
wasmerely Huawei’s local business partner in Iran. In reality, Skycom
was Huawei’s longstanding Iranian affiliate, and Huawei orchestrated the
2007 sale to appear as an arm’s length transaction between two unrelated
parties, when in fact Huawei actually controlled the company that
part of this scheme to defraud, Meng allegedly personally made a
presentation in August 2013 to an executive of oneof Huawei’s major
banking partners in which she repeatedly lied about there lationship
between Huawei and
to the indictment, Huawei reliedon its global banking relationships for
banking services that included processingU.S. dollar transactions
through the United States. U.S. laws and regulations generally
prohibited these banks from processing transactions related to Iran
through theUnited States. The banks could havefaced civil or criminal
penalties for processing transactions that violated U.S. laws or
regulations. Relying on therepeated misrepresentations by Huawei, these
banks continued their banking relationships with Huawei. One bankcleared
more than $100 million worth of Skycom-related transactions through the
United States between 2010 and
furtherance of this scheme to defraud,and as alleged in the indictment,
Huawei and its principals repeatedly lied toU.S. government authorities
about Huawei’s business in Iran in submissions tothe U.S. government,
and in responses to government inquiries. For example, Huawei provided
false information to the U.S. Congress regarding whether Huawei’s
business in Iranviolated any U.S. law. Similarly, asindicated in the
indictment, in 2007 — months before Huawei orchestrated thepurported
sale of Skycom to another Huawei-controlled entity — Huawei’s founder
falsely stated to FBI agents that Huawei did not have any direct
dealings with Iranian companies and that Huawei operated in compliance
with all U.S. export
one of Huawei’s major global banking partners (identified as Financial
Institution 1 in the indictment) decided toexit the Huawei relationship
in 2017 because of Huawei’s risk profile, Huawei allegedly made
additional misrepresentations to several of its remaining banking
partners in an effort to maintain and expand those relationships. Huawei
and its principals are alleged to have repeatedly and falsely claimed
that Huawei had decided to terminate its banking relationship with
Financial Institution 1, when in fact it was Financial Institution 1
that had decided to terminate the banking relationship. Through these
misrepresentations, Huawei wasable to continue its banking relationships
with its other
2017, when Huawei became aware of the government’s investigation, Huawei
and its subsidiary Huawei USA allegedly tried to obstruct the
investigation by making efforts to move witnesses with knowledge about
Huawei’s Iran-based business to the PRC, and beyond the jurisdiction of
the U.S. government, and by concealing and destroying evidenceof
Huawei’s Iran-based business that was located in the United
December 2018, Canadian authorities apprehended Meng in Vancouver
pursuant to a provisional arrest warrant issued under Canadian law. The
U.S. governmentis seeking Meng’s extradition to the United
charges in the indictment are merely allegations, and the defendants are
presumed innocent until proven guiltybeyond a reasonable doubt in a
court of
indictment unsealed today is assignedto U.S. District Judge Ann M.
Donnelly of the Eastern District of New
York.今天公布的起诉书交给了纽约东区的美国地区法官安·m·唐纳利(Ann M.
Donnelly)。The government’s investigation is
ongoing.政府的调查正在进行中。The investigation is being jointly
conducted by the FBI’s New York Field Office, HSI’s New York Field
Office,OEE’s New York Field Office, and DCIS’s Southwest and Northeast
FieldOffices. Agents from the FBI, HSI, andOEE offices in Dallas
provided significant support and assistance. The government’s case is
being handled by the National Security and Cybercrime and Business and
Securities Fraud Sections ofthe U.S. Attorney’s Office for the Eastern
District of New York, the JusticeDepartment’s Criminal Division’s Money
Laundering and Asset Recovery Section(MLARS), and the Justice
Department’s National Security Division’s Counter intelligence and
Export Control Section
U.S. Attorneys Alexander A.Solomon, Julia Nestor, David K. Kessler,
Kaitlin Farrell, and Sarah Evans,MLARS Trial Attorneys Laura Billings
and Christian Nauvel, and CES TrialAttorneys Thea D. R. Kendler and
David Lim are in charge of the prosecution,with assistance provided by
Assistant U.S. Attorney Mark Penley of the NorthernDistrict of Texas,
Assistant U.S. Attorneys Brian Morris and Brendan King ofthe Eastern
District of New York’s Civil Division and Trial Attorneys
AndrewFinkelman and Margaret O’Malley of DOJ’s Office of International
Affairs. Additional Criminal Division and NationalSecurity Division
Trial Attorneys and Assistant U.S. Attorneys within U.S.Attorney’s
Offices for the Northern District of Texas, the Eastern District
ofTexas, and the Northern District of California have provided
valuableassistance with various aspects of this
investigation.……(分工)The Defendants(4名被告):Huawei Technologies
Co. Ltd.Huawei Device USA Inc.Skycom Tech Co. Ltd.Meng Wanzhou, also
known as “Cathy Meng”and “Sabrina Meng”Age: 46Residence: People’s
Republic Of ChinaE.D.N.Y. Docket No. 18-CR-457 (AMD)[1] The indictment
charges other individualswho have not yet been apprehended and whose
names will not be publicly releasedat this time.

International transfer between banks involving newly sanctioned
countries may get interrupted or stuck. The United Nations, European
Union, and the
out with new and updated sanctions on the banking industries of targeted

  1. According to financial statements for Skycom for the years 2009
    and 2010, the “principal activities of Skycom were engaged in [sic]
    investment holding and acting as a contractor for contracts undertaking
    [sic] in Iran.”孟晚舟,英文名Cathy Meng或Sabrina
    to information obtained through an investigation by U.S. authorities,
    including the following, Huawei operated Skycom as an unofficial
    subsidiary to conduct business in Iran while concealing Skycom’s link to
    Huawei. In this manner and as explained in further detail below, Huawei
    could conceal the nature of certain business it was conducting in and
    related to Iran, which is generally considered a high-risk
    employees of Skycom have stated, in sum and substance, that Skycom was
    not distinct from Huawei. For example, Skycom employees had Huawei email
    addresses and badges, individuals working in Iran used different sets of
    stationery (“Huawei” and “Skycom”) for different business purposes, and
    the leadership of Skycom in Iran were Huawei
    show that multiple Skycom bank accounts were controlled by Huawei
    employees, and Huawei employees were signatories on these accounts
    between 2007 and
    and email records show that persons listed as “Managing Directors” for
    Skycom were Huawei
    official documents, including several Memoranda of Understanding, bore
    the Huawei
    correspondence and other records show that all identified Skycom
    business was conducted using “” email addresses;
    show that a purportedly unrelated entity to which Skycom was supposedly
    “sold” in 2009 was actually also controlled by Huawei until at least in
    or about
    records and other documents obtained by U.S. authorities further
    demonstrate that Huawei operated Skycom as an unofficial subsidiary to
    conduct business in Iran while concealing Skycom’s link to Huawei. Among
    other things, records obtained through the investigation show that
    Skycom was used to transact telecommunications business in Iran for
    major Iranian-based telecommunications
    ARREST REQUEST FOR WANZHOU MENG孟晚舟临时逮捕请求书The investigation by
    U.S. authorities has revealed a conspiracy between and among Meng and
    other Huawei representatives to misrepresent to numerous multinational
    financial institutions, including a global financial institution which
    conducts business in the United States (“Financial Institution 1”),
    Huawei’s business practices, particularly Huawei’s control of Skycom in
    or about and between 2009 and 2014. Specifically, Meng and other Huawei
    representatives repeatedly lied about the nature of the relationship
    between Huawei and Skycom and the fact that Skycom operated as Huawei’s
    Iran-based affiliate in order to continue to obtain banking services
    from multinational financial
    motivation for these misrepresentations stemmed from Huawei’s need to
    move money out of countries that are subject to U.S. or E.U. sanctions –
    such as Iran, Syria, or Sudan – through the international banking
    system. At various times, both the U.S. and E.U. legal regimes have
    imposed sanctions that prohibit the provision of U.S. or E.U. services
    to Iran, such as banking services. Of particular relevance, companies
    such as Huawei operating in sanctioned countries often need to
    repatriate income out of those countries by relying on U.S.-dollar
    clearing transactions, which typically pass through the United States,
    or Euro-clearing transactions, which typically pass through E.U.
    countries. Huawei was a customer of Financial Institution 1 and the
    other victim institutions, and conducted a significant amount of its
    international banking activity, including U.S.-dollar-clearing
    transactions, with Financial Institution 1. The financial institutions
    at issue, including Financial Institution 1, maintained policies by
    which they would not onboard Iran-based clients or process Iran-related
    transactions through the United States, so as to avoid exposure to U.S.
    civil and criminal liability. In response to due diligence inquiries by
    the banks regarding these internal policies, Meng and other Huawei
    representatives repeated stated that Huawei did not operate Skycom and
    that, with respect to Financial Institution 1, Huawei would not use
    Financial Institution 1 to process any Iran-related
    Meng and other Huawei representatives misrepresented to Financial
    Institution 1 and the other financial institutions about Huawei’s
    relationship with Skycom, these victim banking institutions were induced
    into carrying out transactions that they otherwise would not have
    completed. As a result, they violated the banks’ internal policies,
    potentially violated U.S. sanctions laws, and exposed the banks to the
    risk of fines and forfeiture. In particular, these relationships
    included the clearing of hundreds of millions of U.S.-dollar
    transactions through correspondent accounts at financial institutions in
    Eurozone countries. In essence, these misrepresentations exposed the
    financial institutions to serious harm and denied the institutions the
    opportunity to make decisions based on the true risk of processing
    certain transaction and the reputations risk associated with banking
    high-risk clients such as
    example, during the relevant timeframe, Financial Institution 1 was
    under investigation for U.S. sanctions violations involving Iran and
    later entered into a deferred prosecution agreement pertaining to U.S.
    sanctions violations involving Iran, and could therefore have suffered
    criminal consequences for processing Huawei’s Iran-based
    on the misrepresentations by Meng and other Huawei representatives,
    Financial Institution 1 and its U.S. subsidiary cleared more than $100
    million worth of transactions related to Skycom through the United
    States between approximately 2010 and
    of the misrepresentations at issue were in direct response to a series
    of articles published by Reuters describing how Huawei controlled
    Skycom, and alleging that Skycom had attempted to import
    U.S.-manufactured computer equipment into Iran in violation of U.S.
    sanctions. One of the Reuters articles reported that Meng was a member
    of the board of directors of Skycom for several years. In statements
    reported in those Reuters articles, Huawei denied control of Skycom or
    violations of
    to information obtained from international financial institutions that
    conducted business with Huawei, after the Reuters articles were
    published, several of them, including Financial Institution 1, asked
    Huawei whether the allegations regarding their control of Skycom and
    business with Iran made in the Reuters articles were true. In response
    to those questions, Huawei employees and executives made a series of
    misrepresentations, both publicly and in private communications, with
    various banking executives, among other things, denying Huawei’s control
    of Skycom and claiming Huawei did not violate U.S. sanctions
    example, after the Reuters articles were published, Financial
    Institution 1 requested that Huawei provide further information and
    clarification regarding the relationship of Huawei and Skycom. Although
    those inquiries were not addressed to Meng, on or about August 2013,
    Meng arranged for a meeting with an executive of Financial Institution
    1, and during that meeting, made a number of misrepresentations to an
    executive of Financial Institution
    that meeting, Meng used an English interpreter and relied on a
    PowerPoint presentation written in Chinese. Meng stated that she was
    using an interpreter to be precise with her language. After the meeting,
    an executive from Financial Institution 1 asked for an English language
    version of Meng’s PowerPoint presentation. Meng arranged for hand
    delivery of the document to Financial Institution 1 on or about
    September 3, 2013. The PowerPoint presentation included numerous untrue
    or misleading representations regarding Huawei’s ownership and control
    of Skycom and Huawei’s compliance with applicable U.S. laws. For
    stated that “Huawei operates in Iran in strict compliance with
    applicable laws, regulations and sanctions of UN, US and EU,” although
    Skycom was using the U.S. financial system to conduct prohibited
    stated that “Huawei’s engagement with Skycom is normal business
    cooperation. Through its trade compliance organization and process,
    Huawei requires Skycom to make commitments on observing applicable laws,
    regulations and export control requirements.” However, as discussed
    above, Huawei did not “cooperate” with Skycom; Skycom was entirely
    controlled by
    Stated that “Huawei was once a shareholder of Skycom, and I [Meng] was
    once a member of Skycom’s Board of Directors. Holding shares and a BOD
    position was meant to better manage our partner and help Skycom to
    better comply with relevant managerial requirements.” However, as
    discussed above, there were no “Skycom” employees who were managed by
    Huawei; Skycom employees were Huawei
    stated that “As there was no process or organization at Skycom, Board
    supervision was the only way to ensure trade compliance. Holding shares
    or assigning Board member could help Huawei to better understand
    Skycom’s financial results and business performance, and to strengthen
    and monitor Skycom’s compliance.” As discussed above, even while Meng
    was on the Board, Huawei did not “monitor” Skycom’s compliance –
    Skycom’s “employees” were effectively Huawei employees who used Huawei
    stated that “Huawei has sold all its shares in Skycom, and I [Meng]
    also quit my position on the Skycom Board.” As discussed, that statement
    was highly misleading because Huawei sold its shares in Skycom to a
    company also controlled by
    only did Meng give this presentation herself, but both the written
    presentation and her oral statements to the executive of Financial
    Institution 1 refer to Meng in the first person, using the word “I”,
    indicating Meng’s personal knowledge of the facts surrounding her
    Meng’s presentation, several Financial Institution 1 risk committees
    relied in part upon Meng’s representations to continue banking Huawei.
    briefing paper from in or about November 2013 stated, “Huawei confirms
    that Skycom is a business partner of Huawei and works with Huawei in
    sales and services in Iran.” The minutes for the meeting reflect,
    “Huawei advised [Financial Institution 1] that its shareholding in
    Skycom was sold in 2009 and that Cathy Meng (CFO Huawei) resigned her
    position on the board of Skycom in April 2009 … [T]he committee agreed
    to RETAIN the relationship with Huawei
    statements are in risk committee briefings from in or about February
    2014 and March 2014. All of the committees relied on Meng’s statements,
    and none of these committees took adverse action related to the Huawei
    relationship with Financial Institution
    executive at Financial Institution 1 stated that Financial Institution
    1’s risk committee decided to retain Huawei as a client because “Huawei
    sold Skycom and the Huawei Chief Financial Officer (CFO) was no longer
    on the Skycom board.” The executive further said that, had Huawei not
    actually sold Skycom, such a fact would have been “material” to deciding
    to exit the client
    or about April 15, 2015, a Financial Institution 1 reputational risk
    committee met in New York City to discuss whether to begin providing
    banking services to a Huawei U.S. subsidiary. Meng’s statement about
    Huawei’s sale of Skycom was presented to that committee, along with
    other information. The committee declined to provide banking services to
    the Huawei U.S.
    misrepresentations personally made by Meng were part of a broader
    conspiracy to misrepresent the relationship between Huawei and Skycom.
    Other Huawei employees and representatives made similar
    misrepresentations to Financial Institution 1 and to at least three
    other global financial institutions. For example, a reputational risk
    report from one of those financial institutions states that “Huawei has
    stated that Skycom is a HK [Hong Kong] local business partner and has
    no further affiliation with Huawei.” Some of these misrepresentations
    were made, involved, or resulted in interstate and foreign wire
    Meng is a citizen of the People’s Republic of China born on February 13,
  2. She is believed to reside in China. She is traveling to Vancouver,
    Canada on Saturday, December 1, 2018, on Cathay Pacific (CX) Flight 838,
    in transit to a third country, believed to be Mexico. She is scheduled
    to arrive at Vancouver International Airport at approximately 11:30 AM,
    PST. Meng will be traveling on a Hong Kong passport bearing passport
    number KJ0403962. The photograph attached to the Request for Provisional
    Arrest was obtained from a publicly available website for HUAWEI
    TECHNOLOGIES CO. LTD, which represents the person depicted as Ms.
    Wanzhou Meng (Sabrina Meng), the Deputy Chairwoman, and
    Meng)女士,担任华为的副董事长及首席财务官。BASIS FOR URGENCY事件紧急The
    United States first obtained information regarding Meng’s travel to
    Canada on November 29, 2018. U.S. authorities believe, based on the
    totality of circumstances, that unless Meng is provisionally arrested in
    Canada on Saturday, December 1, 2018, while in transit, it will be
    extremely difficult, if not impossible, to secure her presence in the
    United States for prosecution. The United States has no extradition
    treaty with the People’s Republic of China, and Meng, who is the CFO of
    one of China’s major corporate entities and the daughter of its founder,
    has significant assets at her disposal. She has the ability to travel
    and remain outside of the United States
    authorities believe that after in or about April 2017, Huawei became
    aware of a U.S. criminal investigation of Huawei when Huawei’s U.S.
    subsidiaries were served with a grand jury subpoena commanding
    production of, among other materials, all records of Huawei’s Iran-based
    business. As a result, Huawei executives began altering their travel
    patterns, to avoid any travel to or through the United States.
    Specifically, high-level Huawei executives, including Meng, have ceased
    traveling to the United States. Although Meng previously traveled to the
    United States multiple times in 2014, 2015, and 2016, her last trip to
    the United States was from late February through early March 2017. Meng
    has not come the United States since then. Moreover, another senior
    Huawei executive came to the United States at least four times between
    2013 and 2016, and has not traveled to the United States since

International transfers play an important role in trading. Lately, some
trading companies in China have failed to receive payments from their
overseas clients because the funds are being sent from sanctioned
countries. In this article, we will give solutions and suggestions to
help lower this risk.

Countries involved in sanction name-list doesn’t mean all international transfers have been interrupted or stopped.

A trading company in China failed to receive deposits from its client in
Russia, that was using the Bank of Moscow to make the transaction. So
far, there are 94 banks in Russia, including one of the country’s
biggest banks the Bank of Moscow, are on the sanction name-list of the
United States.

Apart from these 94 banks, the rest may be ok.How to tell banks in
sanction/sensitive countries can still do international transfers?

Solutions & Suggestions:

Do a test transfer:before the client makes a transaction of deposit
or payment, you can make a small test transfer to make sure there is no
obstacle between the overseas bank and the Chinese domestic bank. You
should especially do this with new customers, without any transaction
record with you.

Inform the bank in China:give early notice to the bank, which your
client is going to make the transfer to China. Check any sanction
information about the bank and balance your risk.

Clearly sanctioned countries are no-go:If it isn’t necessary, do not
transfer with countries which are CLEARLY on the sanction name-list.

Use banks you have used before with a client:If your clients are in
some sensitive countries and the previous international transaction went
well, it would be better to use the same bank for the following
transactions. And don’t forget to check the bank regularly.

Documents against Payment(DP) is risky for exporters:for instance,
the cargo arrives at the destination port, yet the
not get B/L from the bank due to things like financial problems or the
international transfer is stuck between banks. In such a situation, the
exporter may have no idea how to deal with the cargo. Generally, most
exporters require 30% prepayment from clients before shipping under DP.

Buy insurance and don’t gamble:accidents on international transfer
are included in the catalog of certain insurance companies. It may help
you mitigate financial loss. Add this expense to any dealings with
sensitive countries. If the added insurance costs make the deals not
profitable, it is better to let the deals go, then risk losing whole

Name-list of countries for high risk of international banking transfer issues.

Sanction name-list can be checked here:

Countries like Iran, Sudan, North Korea, Syria, and Cuba are clearly on
the sanction name-list. Most Chinese domestic banks will refuse to work
on the international transaction with these countries. Some regional
branches of the same bank will have their own policies and may allow
these transfers.

Most of the domestic banks are not willing to be involved in any
troubles or even the hint of an issue. Standards to deal with
transactions of USD among some sensitive countries are unclear.
Especially since July when CRS was launched in China to fight against
money laundering and tax evasion. Domestic banks now manage
international transactions much more carefully.

The infographic below is the latest unconfirmed name-list of countries
for high risk of international banking transfer issues. This list is
unconfirmed by officials, and it is released by people working in
international trading.

澳门新萄京客户端下载 1

Using MoneyGram/Western Union are recommended to make international
transfers to countries above. If transferred by the bank, you may be
required to provide some documents to prove you are a legal business.

Required documents depend on the policies of different banks, most of
the case include

  1. Against Money Laundering Questionnaire

  2. Risk Commitment Letter

  3. Explanation Letter: the business relationship between exporter,
    importer, including the third party if participating in this trading

One point should be specified:The cargo should not stop by the port
of Iran and the company must take the responsibility of any resulting
economic disputes and their consequences. It has nothing to do with the

If you have good ideas on international transfer, please free feel to
leave a comment below and share with us, let’s make business easy.

Reference: Sina Sohu, 浙江外贸,贸易金融观察