Saxo Group Sanctions Policy

Sanctions are a foreign policy tool used by national governments, such as the UK and US and supranational organizations and bodies, like the European Union (“EU”) and United Nations, to influence the behavior of actors in order to achieve foreign policy objectives and maintain international peace and security. There are various sanctions programs imposed across the globe, many of which prohibit or limit trade or other economic activity with certain countries, geographical areas, governments, entities, organizations and individuals.

Compliance with sanctions is an integral part of the overall financial crime strategy of Saxo Bank A/S and its group of companies, including Saxo Capital Markets Pte. Ltd. (the “Saxo Group”). It is the policy of the Saxo Group to not engage in prohibited activities or transactions with individuals, entities or countries subject to sanctions in jurisdictions where the Saxo Group operates. This allows the Saxo Group to manage and mitigate our risk exposures, and protect the Saxo Group and its clients from financial or reputational damage, regulatory censure, fines and enforcement actions. Importantly, this allows us to continue serving and providing our clients, including our market access and liquidity providers, customers and counterparties, access to global markets. These are all essential prerequisites for the success of our clients and the Saxo Group.

Everyone in the Saxo Group is responsible for complying with this policy and ensuring that its requirements are met, including:

• All employees, consultants, contractors and temporary staff; and 
• Wholly owned and majority owned subsidiaries, branches and representative offices.

The Saxo Group adheres to the sanctions laws and regulations issued by the following competent authorities globally:

• Australia
• EU¹
• Hong Kong
• Japan
• United Kingdom
• United Nations
• United States
• Singapore
• Switzerland

This policy means that by default, parties or activities prohibited under any of the above regimes must not be engaged with in any capacity. This restriction applies irrespective of the legal applicability of the specific sanctions to the business activity.

Further, the Saxo Group expects all parties with whom it maintains any relation not to engage in, or facilitate any business that causes Saxo Group to violate or circumvent this policy or any applicable sanction laws and regulations directly or indirectly. The Saxo Group shall have the right, under this policy, any terms entered into between the client and the Saxo Group, or Singapore laws, to undertake any actions to protect the rights and interests of the Saxo Group and/or its clients. 

This policy choice can be amended and altered, at any time without notice, in line with the international sanctions environment and the Saxo Group’s risk appetite.

¹ Including those issued by Belgium, Czechia, Denmark, France, and Netherlands independently of the EU