Sanctions measures foreign countries
Doing business with foreign countries or conducting transactions with parties subject to sanctions may result in a transaction not being able to be carried out or that additional information is required to carry out the transaction. This article provides information about sanctions and what the possible consequences are.
What are sanctions?
Sanctions are measures taken by the international community in response to a breach of, or threat to, international peace and security. They are intended to influence or change the behaviour of a country, organisation or person.
Sanctions may result in restrictions on certain countries, persons, organisations, goods or services. Examples of sanctions include:
Financial sanctions: for example, freezing bank accounts or other assets. Investment in certain countries may also be prohibited.
Trade restrictions: for example, a ban on trading certain goods, such as technology or raw materials from which a country earns significant revenue or which it needs for warfare.
Arms embargoes: a ban on the import and export of military goods.
Travel and visa restrictions: for example, preventing certain individuals from travelling to the EU.
ABN AMRO adheres to international sanctions measures, including the sanctions regimes of the , the and the . ABN AMRO also adheres with local sanctions laws and regulations in the countries in which the bank operates and applies its own sanctions policy.
What do we expect from you?
Check in advance whether sanctions apply to the parties and countries involved in your transaction. Consult the relevant laws and regulations and available sources of information to determine whether financial sanctions, trade restrictions and/or arms embargoes apply.
The same rules apply to payments as to the goods, services and technology subject to trade restrictions. These payments are not permitted if the underlying trade in, or activities involving, products, services or technologies are prohibited.
What is not permitted?
Sanctions are effective only if everyone complies with them and they are not breached or circumvented. Breaching or circumventing sanctions is a criminal offence. You must not, knowingly or unknowingly, carry out acts that conflict with sanctions laws and regulations or are intended to evade sanctions.
Circumvention means rerouting payments or goods in order to evade sanctions laws and regulations, directly or indirectly. Examples include:
Importing or exporting products subject to sanctions for a particular country by routing them indirectly.
Failing to investigate sufficiently who the end user of sanctioned products is.
Making or receiving payments through an intermediary where the ultimate beneficiary or payer is a sanctioned individual, organisation or other sanctioned party.
Using false documents to conceal the origin or destination of goods.
Changing a company’s ownership or control structure to conceal that a sanctioned individual is the ultimate beneficial owner.
Knowingly ignoring indications that a transaction, payment or trading activity may be connected to a sanctioned party, country, product or service.
Keep up to date with changes
The websites of the competent authorities provide the most up-to-date information on the sanctions that apply, including:
Other useful sources of information include:
Additional ABN AMRO policy
In addition to external sanctions laws and regulations, ABN AMRO applies its own sanctions policy. Based on our risk assessment, we may apply stricter measures than those set out in regulatory sanctions regimes. ABN AMRO applies a stricter internal sanctions policy to trade, activities and transactions involving the countries listed below.
Please note: in some cases, ABN AMRO uses one or more correspondent banks to process your transaction. These correspondent banks may apply a different sanctions policy. This may mean that your transaction is delayed or not processed.
Additional information on trade restrictions
A range of requirements and restrictions apply to the import and export of goods and services. A licence may be required, while trade in certain goods or the provision of certain services and technologies may also be prohibited in whole or in part.
Check in advance whether sanctions apply to the parties and countries involved. Trade restrictions may arise from EU regulations, each of which specifies the goods, services and technologies subject to sanctions.
Trade restrictions may also arise from national legislation. Rules imposed by other countries, such as the US Export Administration Regulations (EAR), may also apply where there is a relevant connection with that country or those regulations.
Common categories of products, services and technology subject to trade restrictions include:
Military goods: products that can be used directly for military purposes, such as weapons and ammunition, combat vehicles, military electronics, radar and communications systems, etc.
Dual-use goods: goods, software and technology that can be used for both civilian and military purposes. Examples include advanced electronics and semiconductors, encryption software, drones, navigation equipment, precision tools and machine parts, and chemical and biological materials.
Energy and raw materials: sanctions may target commodities such as oil and petroleum products, natural gas, coal, metal ores and precious metals, including gold.
Luxury goods: some sanctions restrict or prohibit the export of luxury goods such as luxury cars, jewellery and watches, designer clothing, luxury accessories and alcoholic beverages above a certain value.
Technology and telecommunications: sanctions may target technology and telecommunications, such as computers and servers, network equipment, telecommunications technology, artificial intelligence technology and advanced chips.
Chemical and industrial products: sanctions may target chemical and industrial products, such as chemicals, industrial machinery, production equipment, and equipment or installations for refining or power generation.
Financial and related materials: sanctions may also target services and digital applications, such as software for financial transactions, cryptocurrency-related services and financial services connected with international trade.
Useful sources of information include:
Information on Russia and Belarus
Extensive sanctions are in place. These include financial and trade sanctions. In addition, the EU has imposed several financial restrictions on Russian and Belarusian individuals and organisations.
The trade sanctions cover a very wide range of products, services, technologies and sectors. Even an everyday product may fall within the sanction’s regulation. Transactions connected with prohibited trade in goods are not permitted because the underlying activity is prohibited. Circumventing these measures is also prohibited.
We may require additional information and/or documentation from you to assess whether these regulations apply. We may also be unable to process certain transactions.
More information is available on the websites of:
Contact
Do you have questions about ABN AMRO sanction measures? Contact your adviser or via 0900 - 0024.