Amsterdam Trade Bank N.V. (ATB) is committed to its responsibility to act in compliance with international sanctions. We have developed internal policies and procedures, together with our correspondent banks, to ensure that ATB accounts are operated in full compliance with said regulations and sound banking practices. The EU and US sanctions are drafted in wide and sometimes imprecise terms with little associated guidance. This means that there is often uncertainty as to how the EU and US authorities interpret the restrictions set out in the relevant sanctions legislation. Enforcement priorities are also based on a multitude of factors, including but not limited to foreign policy, the prevailing geopolitical situation and resources of the enforcing agency. Furthermore said regulation may change from time to time. ATB closely monitors the regulatory developments in the EU and the US.
In addition to the legally imposed sanctions we furthermore have to comply with the, sometimes even more challenging, requirements from our correspondent banks to execute your international payments.
Based upon the current sanctions and arrangements with correspondent banks ATB has:
a) No appetite for transactions with clients located, domiciled or registered and/or clients owned/controlled by persons located, domiciled or registered (including government or any sub division thereof), in Cuba, Crimean Region of Ukraine, Eritrea, Iran, Libya, North Korea, Sudan (and South Sudan), Somalia, and Syria. ATB will not execute any payment to and/or from (legal) persons located, domiciled or registered in these countries.
b) Limited appetite for transactions with clients located, domiciled or registered and/or clients owned/controlled by persons located, domiciled or registered (including government or any sub division thereof), in Afghanistan, Democratic Republic of the Congo, Iraq, Lebanon, Myanmar, Pakistan, Palestinian Territories, Russia, Ukraine, Yemen and Zimbabwe. This limitation means, that execution of any payment to and/or form (legal) persons located domiciled or registered in these countries is dependent on the type of transaction and subject to prior explanation and documentation.
It is not allowed to participate, knowingly or intentionally, directly or indirectly, in activities the object or effect of which is to circumvent the above.
Indirectly means that there is a factor that creates a nexus not directly caused by or resulting from an event, incident, or occurrence. An example: One of our correspondent bank has no appetite for payments related to transactions involving a vessel docked in Iran less than 365 days before the anticipated payment. We acknowledge that the term ‘indirectly’ may lead to uncertainty.
Any question and/or remark can be sent to the relationship manager.
Amsterdam Trade Bank N.V. (ATB) has been a member of the Dutch banking community since 1994 and is regulated by The Dutch Central Bank (De Nederlandsche Bank or DNB) and by the Netherlands Authority for the Financial Markets (Autoriteit Financiële Markten or AFM). We adhere to the highest integrity standards for corporate and individual behaviour.
The Wolfsberg Group, an association of eleven global banks, established a template Anti-Money Laundering (AML) Questionnaire which aims to provide a standardised overview of a financial institution's AML policies and practices. Read ATB's responses to the questionnaire*.*Fully signed versions will be furnished upon request.