Sanctions Screening & Compliance Policy

Policy Statement

The Company is committed to adhering to all applicable sanctions laws, regulations, and guidelines issued by national and international authorities. This Sanctions Screening & Compliance Policy establishes a framework to prevent the Company from engaging, directly or indirectly, with sanctioned individuals, entities, or countries. The policy ensures compliance with the Office of Foreign Assets Control (OFAC), United Nations (UN), European Union (EU), and Indian regulatory requirements.

Objective

• Ensure compliance with sanctions laws and regulations applicable to the Company's operations.
• Prevent transactions or relationships with sanctioned individuals, entities, or jurisdictions.
• Define screening and monitoring procedures for customers, vendors, and business partners.
• Establish reporting mechanisms for potential sanctions violations.

Regulatory Framework

• United Nations Security Council (UNSC) Sanctions Lists.
• Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury.
• European Union (EU) Consolidated Sanctions List.
• UK Office of Financial Sanctions Implementation (OFSI) List.
• Reserve Bank of India (RBI) and Ministry of Finance, Indian sanctions directives.
• Prevention of Money Laundering Act (PMLA), 2002 and related AML/KYC guidelines.

Scope and Applicability

This policy applies to all departments, employees, subsidiaries, and third-party partners of the Company It covers all customer onboarding, vendor engagement, transaction processing, and cross-border business dealings.

Sanctions Screening Framework

The Company shall maintain an automated and manual sanctions screening framework to identify individuals or entities listed on global sanctions lists. The screening process shall include customers, vendors, employees, and counterparties at onboarding and periodically thereafter.

• Screening of names against global and domestic sanctions lists (OFAC, UN, EU, RBI, etc.).
• Continuous monitoring for updates to sanctions lists and rescreening of existing relationships.
• Risk-based assessment for politically exposed persons (PEPs) and high-risk jurisdictions.
• Periodic testing and validation of the screening software and procedures.

Transaction Screening

All financial and non-financial transactions shall be screened before execution to ensure compliance with sanctions requirements. Transactions involving sanctioned countries, entities, or individuals shall be automatically flagged, reviewed, and reported to the Compliance Officer.

Handling of Positive Matches

• The Compliance Department shall verify the accuracy of all screening alerts and determine if they represent a true match.
• In the event of a confirmed match, the account or transaction shall be immediately frozen or suspended.
• The matter shall be escalated to the Principal Officer and relevant authorities, such as the RBI or FIU-IND.
• Documentation of all alerts, investigations, and outcomes shall be maintained for a minimum of five (5) years.

Record Keeping and Reporting

All sanctions screening results, alerts, and investigation reports shall be securely stored for audit and regulatory review. Reports of confirmed matches shall be submitted to the relevant authorities as per applicable timelines.

Roles and Responsibilities

• Board of Directors: Ensure a culture of compliance and approve the sanctions policy framework.
• Principal Officer: Serve as the point of contact for authorities and oversee sanctions compliance.
• Compliance Officer: Conduct periodic screening, review alerts, and ensure training and awareness programs.
• Employees: Adhere to this policy and immediately report any suspected sanctions violations.

Training and Awareness

The Company shall provide regular sanctions compliance training to all employees involved in customer onboarding, transaction processing, and vendor management. The training will cover identification of sanctioned entities, reporting obligations, and consequences of violations.

Penalties and Consequences

Non-compliance with this policy may result in severe penalties, including regulatory fines, restrictions on operations, or criminal prosecution. Employees involved in willful violations will face disciplinary action up to and including termination.

Policy Review

This policy shall be reviewed annually or whenever there are changes in sanctions laws, regulatory requirements, or operational structures. All updates shall be approved by the Board of Directors and communicated across the organization.

Employee Acknowledgment

I acknowledge that I have read and understood the Sanctions Screening & Compliance Policy of the Company I agree to comply with the provisions and report any potential sanctions-related concerns in accordance with Company procedures.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________