The Sultanate of Brunei has adopted Sharia Law, to be applied in stages, for criminal offenses. Inasmuch as some of the prescribed punishments, such as stoning to death, and dismemberment, are deemed to be cruel and unusual by most of the members of the United Nations. Your problem as a compliance officer is that you may have a real problem sending any due diligence investigator into Brunei, to vett a prospective client. Have you ever lost anybody in the field ? Trust me, it is not something I recommend.
What if, in ignorance of the newly-enacted Draconian punishments, a Western bank staff member sent into the field in Brunei, commits a crime deemed to be a capital offense ? And remember, extra-marital sex and homosexuality are among the crimes listed in Sharia. Chopping off hands interferes with compliance functions. Will any other investigators ever dare to conduct due diligence there ? I seriously doubt it. The existence of Sharia Law will definitely impede the ability of foreign banks to conduct on-site investigations.
Under the circumstances, you should (1) Raise Country Risk on Brunei, and (2) Ban any trips or visits by your officers and staff, no exceptions, unless they are observant Muslims, and accept the assignment, understanding that Sharia is in force there.
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