The Workplace Relations Commission found that a bank indirectly discriminated against an Iranian customer by requiring her to sign a declaration restricting transactions connected with Iran. It ordered the bank to pay her €12,000 and review and amend its enhanced due diligence procedures.
The decision, dated 22 May 2018, concerned the customer’s complaint under the Equal Status Act. She had held an account with the bank for 10 years and said the declaration would prevent her using it for personal and business activity involving Iran. It also required her to indemnify the bank against losses if she breached its terms.
The bank said its checks were needed to meet anti-money laundering, terrorist financing and sanctions obligations. The WRC accepted that the bank had legitimate aims but found the restrictions were neither appropriate nor necessary. The customer had explained her transactions and provided supporting documents, while the bank had not considered alternative safeguards.