For the purposes of evaluating the feasibility of a potential customer relationship with Membrane Finance, we identify certain countries as “High-Risk States”. Customers based in or affiliated with any of the High-Risk States are ineligible for onboarding as a customer to Membrane Finance.
High-Risk States
High-Risk State means the states identified by The EU Commission in its delegated regulations (EU) 2016/1675 and (EU) 2024/163, and the as high-risk third countries that are associated with increased Risks. Additionally, High-Risk States include countries identified by Membrane Finance as countries associated with increased risks and exclude all EU member states. As of 14 May 2024, High-Risk States consist of the following countries:
Afghanistan
Barbados
Botswana
Burkina Faso
Cameroon
Central African Republic
People’s Republic of China
Congo Democratic Republic
Cuba
Eritrea
Ethiopia
Guinea-Bissau
Iran
Iraq
Lebanon
Libya
Ghana
Gibraltar
Guam
Haiti
Jamaica
Kenya
Jordan
Mali
Mozambique
Myanmar
Namibia
Nigeria
Democratic Republic of Korea
Panama
Philippines
Puerto Rico
Russia
Senegal
Somalia
South Africa
South Sudan
Sudan
Syria
Tanzania
Turkey
Trinidad and Tobago
Uganda
United Arab Emirates
United States of America (including American Samoa and US Virgin Islands)
Vanuatu
Vietnam
Yemen
Exemptions regarding High-Risk States
Exemptions regarding High-Risk States means such High-Risk States that have regulatory frameworks stringent enough to warrant service provision in certain instances. Examples of exemptions and the rationale behind the exemptions are included in the below sections.
United Arab Emirates (UAE)
The UAE has demonstrated a high-level commitment to cooperate with the FATF and MENAFATF since February 2022, they have made substantial progress in understanding and mitigating money laundering and terrorist financing risks across different sectors. The UAE continues to actively implement its FATF action plan, including:
1. Maintaining a sustained increase in applying effective, proportionate, and dissuasive sanctions for financial institutions and designated non-financial businesses and professions failing to comply with AML/CFT requirements. Furthermore, they have embraced risk-based customer due diligence and increased the quality and quantity of suspicious transaction reports.
2. Consistently imposing adequate and effective sanctions for breaches related to beneficial ownership obligations.
3. Ensuring ongoing effectiveness in investigating and prosecuting various money laundering cases, aligned with the UAE's unique risk profile, resulting in the application of dissuasive, effective, and proportionate sanctions.
Therefore, UAE will be considered an exception and services may be provided there, with the correct Risk Mitigation Measures.