Sanctions measures in foreign countries

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. Investing 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 persons from travelling to the EU.

ABN AMRO adheres to international sanctions measures, including the sanctions regimes of the United Nations (UN), European Union (EU) and the United States (US). ABN AMRO also adheres with local sanctions laws and regulations in the countries in which the bank operates and applies its own sanctions policy.

Check in advance whether sanctions apply to the parties and countries involved in your transaction. Consult the relevant sanctions laws and regulations and available information sources to determine whether any financial sanctions, trade restrictions and/or arms embargoes apply.

The same rules apply to payments as to the goods, services and technology that are subject to trade restrictions. These payments are not permitted if the underlying trade in, or activities involving, products, services or technologies are prohibited.

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:

• Making or receiving payments through an intermediary when the ultimate beneficiary or payer is a sanctioned person, organisation or other sanctioned party.
• Sending or receiving products that are subject to sanctions for a country via an indirect route via another country.
• Using false documents to conceal the origin or destination of goods.
• Knowingly ignoring indications that a transaction, payment or trading activity may be connected with a sanctioned party, country, product or service.

The websites of the competent authorities provide the most up-to-date information on the sanctions that apply, including:

• The United Nations (UN)
• The European Union (EU)
• The United States (US) 

Other useful sources of information include:

• EU Sanctions Helpdesk
• Government of the Netherlands | International sanctions

In addition to external sanctions laws and regulations, ABN AMRO applies its own sanctions policy. Based on our risk analysis, 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.

Extensive sanctions are in place. These include financial and trade sanctions. In addition, the EU has imposed several financial restrictions on Russian and Belarusian persons and organisations.

We may need additional information from you to assess whether these sanctions apply. We may also be unable to process certain transactions.

One of the regulations is that the total balance held with ABN AMRO may not exceed €100,000 for Russian and Belarusian nationals, persons residing in Russia or Belarus, or legal persons, entities or bodies established in Russia or Belarus.

These regulations do not apply to persons with a valid passport, identity card, or fixed-term or permanent residence permit for the European Union, Norway, Iceland, Liechtenstein or Switzerland.

For Russian nationals or residents, this requirement is laid down in ‘EU Regulation (EU) 833/2014, Article 5b’. For Belarusian nationals or residents, this requirement is laid down in ‘EU Regulation (EU) 765/2006, Article 1u’. More information is available on the websites of:

• European Commission | Deposits
• European Commission | Sanctions adopted following Russia’s military aggression against Ukraine
• The European Union (EU) | EU Sanctions Map

Do you have any questions about transferring money to, or receiving money from, a country that is subject to sanctions (restrictions)? Please contact us.