• Home
  • Products & Services
    Regulated stablecoinsBlockchain integrationsEUROe ↗eUSD ↗
  • Blog
  • Careers
  • Open an account

Country Risk Policy

Updated 2024-05-14

Terms of Membrane PlatformPrivacy NoticeEnd User TermsCountry Risk PolicyAccess Denial Policy

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.

Membrane Finance Oy
Meritullinkatu 1, FI-00170 Helsinki

  • PRODUCTS
  • EUROe
  • eUSD


  • SERVICES
  • Regulated Stablecoins
  • Blockchain Integrations


  • RESOURCES
  • Blog
  • Pricing
  • EUROe Developer Portal
  • EMT RESOURCES
  • Marketing Communications
  • White Papers
  • Offerors


  • LEGAL & REGULATORY
  • Legal
  • Privacy Notice
  • Licences
  • MEMBRANE FINANCE
  • Careers
  • Company
  • Contact


  • FOLLOW US
  • Twitter
  • LinkedIn

Membrane Finance Oy is an electronic money institution regulated by the Finnish Financial Supervisory Authority and authorised across the EU and EEA. Business ID FI32368862. LEI code 743700KYSSTKZYGEUF50.

No investment advice. The information provided on this website does not constitute investment advice, financial advice, trading advice, or any other sort of advice as defined in the Finnish Act on Investment Services (2012/747) or the European Markets in Financial Instruments Directive 2 (2014/65/EU) and you should not treat any of the website contents as such. The information on this website is general in nature and is not specific to you or any other user. You should not make any decision, financial, investment, trading or otherwise, based on the information presented on this website. Membrane Finance does not recommend that any virtual asset should be bought, sold or held by you. We strongly encourage you to conduct independent due diligence and consult your financial and/or legal advisor before making any investment decisions.

Accuracy of information. Membrane Finance will strive to ensure the accuracy of the information listed on this website, although it will not hold any responsibility for any missing or wrong information. Membrane Finance provides all information as is. You understand that you are using all information available here at your own risk and without any express or implied warranty of any kind, including warranties of accuracy, completeness, or fitness for any particular purpose.

This marketing website has been published by Membrane Finance Oy

Privacy Notice
© 2024 Membrane Finance Oy. All rights reserved.