International organisations and authorities including the United Nations and the European Union, and local and national governments, are empowered to impose restrictive measures on countries, organisations, legal persons and individuals implicated in or suspected of breaches of human rights or international law, criminal activities, terrorism, money-laundering, etc.

These measures are generally known as “sanctions” or “embargos”.

AMFIE has a duty to comply with the applicable laws and regulations, and with the obligations implicit in them, and may on occasion be more strict than the rules require.

An embargo is a restrictive measure or sanction adopted at national and/or international level.

Although the provisions vary according to countries, persons and institutions, we can distinguish two types of embargo:

• Financial embargos, which impose restrictions on financial transactions and financial resources;
• Trade embargos, which impose restrictions on the import or export of certain goods, or trade with certain countries or partners.

AMFIE must respect not only the financial and trade embargos imposed by the United Nations (and given legal effect in the Grand Duchy of Luxembourg), the European Union and the Luxembourg Parliament, but also those edicted by third countries which AMFIE regards as important such as the United States (OFAC).

For further information on UN, EU and OFAC sanctions please follow the links at the end of this document.

Observing the rules on embargos means that AMFIE will not provide funds or financial resources to individuals, government agencies or bodies figuring on embargo lists and will play no part in any transaction involving such counterparts.

AMFIE may make the execution of certain transactions and certain payments subject to the member’s production of additional information or documentation relating to the requested transactions and the counterparts concerned.

It should be noted that AMFIE’s correspondent banks also have the duty to suspend any transaction if their monitoring system detects a potential embargo breach. If one of AMFIE’s correspondent banks suspends a transaction, the Association will intervene only as the intermediary between the member and the correspondent bank, and will not be able to influence the inquiry’s outcome.

To avoid any difficulties, AMFIE members planning to conduct business with countries which are the subject of restrictive measures are invited to consult the Association first. 

For more information about applicable embargos or on the Association’s specific policies, please consult your AMFIE contact person.

For reasons of internal policy and risk evaluation, AMFIE has chosen to be stricter than the legally applicable sanctions programmes require, and to apply a stricter embargo policy.

If you have any questions regarding our policy vis-à-vis any specific country you should therefore always refer to AMFIE.

AMFIE will systematically examine in depth the details of any transaction in order to ascertain that it is lawful and falls within the limits of the Association’s own policy.

The details of policy regarding each country can change at any moment as a result of changes in regulations or the political situation.

Find here all the countries affected by these sanctions:

UN: https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list

EU: http://ec.europa.eu/dgs/fpi/what-we-do/sanctions_en.htm

US (OFAC): http://www.ustreas.gov/offices/enforcement/ofac/sdn/

Restrictions on the transfer and/or receipt of funds to or from countries subject to embargo*

Afghanistan
Following the Taliban takeover of the country and in particular of the apparatus of the Afghan state, AMFIE has decided not to process any payment or transaction relating to Afghanistan.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

Belarus
Sanctions against Belarus are highly diverse and extensive. Moreover, EU and third country sanctions are widely divergent and cover different businesses, companies, activities, individuals and entities. AMFIE will accordingly process payments only for its members, and only after a detailed examination of the transaction (whether for trade or a retail purchase) in order to ascertain that it is lawful and falls within the limits of the Association’s own policy.
Financial transactions to or from sanctioned individuals and entities will not be processed by AMFIE; nor will any of the following or any associated financial transactions, regardless of the currency:
- Transit (“pass-through”) transactions
- Financial assistance for specific transactions relating to goods which are the subject of a trade embargo, such as arms and associated military hardware; equipment, technology and software used for surveillance or interception of internet or telephone communications; dual-use items, petroleum products, potash and potassium chloride (for fertilizers); etc.;
- Specific operations involving sanctioned financial services and/or instruments on behalf of the Belarusian government or sectorally-sanctioned banks.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

Crimea
AMFIE will not process any payment in USD, CAD or GBP involving counterparts in Crimea. AMFIE applies certain restrictions to payments in currencies other than USD, CAD and GBP involving counterparts in Crimea. For further details, please consult your AMFIE contact person.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

Cuba
AMFIE will not process any payment in USD, CAD or GBP involving counterparts in Cuba. For its own members, AMFIE will process payments in currencies other than USD, CAD and GBP only after examining in depth the details of any transaction in order to ascertain that it is lawful and falls within the limits of the Association’s own policy. For further details, please consult your AMFIE contact person.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

Iran
AMFIE does not accept funds originating in Iran other than those paid by an international organisation or assimilated organisation.
Transfers to Iran will not be authorised.

Myanmar/Burma
AMFIE will not process any financial transaction involving sanctioned individuals or entities in Myanmar/Burma, regardless of the currency, nor any concerning the sale, delivery or export of the following items to Myanmar/Burma:
- Military equipment and assimilated
- Dual-use items, both civilian and military
- Equipment, technology and software included in the sanctions list and used principally for surveillance or interception of internet or telephone communications both incoming and outgoing.
AMFIE will process financial transactions involving Myanmar/Burma only after examining in depth the details of any transaction in order to ascertain that it is transparent and lawful, and falls within the limits of the Association’s own policy.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

North Korea
AMFIE will not process any payment or other transaction involving North Korea.

Russia
Embargo measures against the Russian Federation are wide-ranging and specific.
EU and OFAC sanctions differ widely.
In consequence, AMFIE will examine the details of any transaction involving Russia in depth in order to ascertain that it is lawful and falls within the limits of the Association’s own policy. For further details, please consult your AMFIE contact person.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

Syria
AMFIE will not process any payment in USD, CAD or GBP involving counterparts in Syria. For its own members, AMFIE will process payments in currencies other than USD, CAD and GBP only after examining in depth the details of any transaction in order to ascertain that it is lawful and falls within the limits of the Association’s own policy. For further details, please consult your AMFIE contact person.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

Venezuela
Sanctions against Venezuela are highly diverse: measures imposed by the EU and third countries cover a wide range of activities, persons, entities and currencies. AMFIE’s embargo policy vis-à-vis Venezuela is accordingly as follows:
AMFIE will not process any payment in USD, CAD or GBP involving Venezuelan counterparts. For its own members, AMFIE will process payments in currencies other than USD, CAD and GBP only after examining in depth the details of any transaction in order to ascertain that it is lawful and falls within the limits of the Association’s own policy. For further details, please consult your AMFIE contact person.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

Sudan and South Sudan
Most sanctions against Sudan and South Sudan have now been lifted, with the exception of those targeting individuals or entities, and asset-freezes. In consequence, and regardless of the currency, AMFIE will process payments only for its members, and only after a detailed examination of the transaction (whether for trade or a retail purchase) in order to ascertain that it is lawful under the applicable sanctions.
It remains possible that some of AMFIE’s correspondent banks may apply more restrictive measures.

* Status in January 2022

Restrictions on the provision of services to residents of countries subject to embargo

Residents of the following embargoed countries are not eligible for AMFIE* membership:

- Afghanistan
- Belarus
- Crimea
- Cuba
- Iran
- Myanmar/Burma
- North Korea
- Russia
- Syria
- Venezuela
- Sudan and South Sudan

*status in January 2022