Sanctions & Prohibited Activities Policy

Sanctions & Prohibited Activities

Our policy on sanctions compliance, restricted jurisdictions, and prohibited trading activities

100%

Screening Coverage

Real-time

Sanctions Checks

Zero

Tolerance Policy

24/7

Monitoring

Policy Overview

We maintain a zero-tolerance policy for sanctions violations and prohibited activities. This policy ensures full compliance with international sanctions regimes and protects our platform from illicit use.

Core Commitments

No services to sanctioned countries or entities
Immediate blocking of prohibited activities
Continuous monitoring and screening
Cooperation with law enforcement

Applicable Sanctions Regimes

• United Nations Security Council Sanctions
• European Union Sanctions
• US OFAC Sanctions (SDN List)
• UK HM Treasury Sanctions
• FATF High-Risk Jurisdictions

Screening Effectiveness

Customer Screening 100%

Transaction Screening 100%

Wallet Address Screening 100%

Real-time Monitoring 24/7

Automated Blocking

All matches against sanctions lists result in immediate automatic blocking and mandatory review.

Sanctioned Countries & Entities

Comprehensive Sanctions

Countries under full embargo

Prohibited Jurisdictions

We do not provide services to individuals or entities from the following countries:

🇰🇵 North Korea (DPRK)

🇮🇷 Iran

🇸🇾 Syria

🇨🇺 Cuba

Crimea Region

Donetsk/Luhansk

FATF High-Risk

Countries identified by FATF as high-risk for money laundering and terrorist financing are subject to enhanced due diligence or prohibition.

Targeted Sanctions

Specific entities and individuals

Screened Lists

OFAC SDN (Specially Designated Nationals)

EU Consolidated Sanctions List

UK Sanctions List (HMT)

UN Security Council Sanctions

Interpol Wanted Lists

Prohibited Entities

• Designated terrorists and terrorist organizations
• Politically Exposed Persons (PEPs) from high-risk countries
• Entities owned/controlled by sanctioned persons
• Individuals on criminal watchlists

Updated Daily: Sanctions lists are updated in real-time as changes are published by authorities.

Prohibited Trading Activities

Illicit Activities

Money laundering
Terrorist financing
Fraud or scams
Drug trafficking proceeds
Human trafficking
Weapons trafficking

Market Manipulation

Wash trading
Spoofing or layering
Pump and dump schemes
Front running
Price manipulation
Coordinated trading

Unauthorized Use

Stolen funds or assets
Hacked cryptocurrency
Proceeds of cybercrime
Unauthorized access
Identity theft
Account takeovers

Privacy Abuse

Darknet market transactions
Cryptocurrency mixers/tumblers
Privacy coins for illicit use
Obfuscation services
Chain-hopping to hide origins

Regulatory Violations

Tax evasion
Securities fraud
Unlicensed money transmission
Insider trading
Ponzi/pyramid schemes

Other Prohibited

Gambling (unlicensed)
Adult content services
Ransomware payments
Counterfeit goods
Intellectual property theft

Screening & Enforcement Procedures

Onboarding Screening

Pre-Approval

All customers are screened against sanctions lists before account approval.

Name matching against all lists

Geographic location verification

PEP and adverse media checks

Screening Result

Match Found: Account Denied

False Positive: Manual Review

No Match: Proceed to KYC

Ongoing Monitoring

Continuous

Existing customers are continuously rescreened as sanctions lists are updated.

Screening Frequency

• Real-time: Every transaction

• Daily: All active accounts

• Weekly: Dormant accounts

• Immediate: List updates

Monitoring Scope

Customer Rescreening Daily

Wallet Screening Real-time

Enforcement Actions

Immediate

Any match against sanctions lists triggers immediate enforcement actions.

Account Freeze

Immediate suspension of all account activities

Transaction Blocking

All pending transactions cancelled

Regulatory Notification

Authorities notified as required by law

Action Timeline

Account Suspension Immediate

Compliance Review 24 hours

Authority Reporting 48 hours

No prior notice given for sanctions-related account actions

Reporting & Law Enforcement Cooperation

SAR Filing

Suspicious Activity Reports filed with FIU Estonia for all detected violations and potential sanctions breaches.

Response Time: <48 hours

Law Enforcement

Full cooperation with law enforcement agencies investigating sanctions violations and prohibited activities.

Data Retention: 7 years

User Reporting

Users can report suspicious activities or potential sanctions violations through our compliance hotline.

Anonymity: Protected

Important Notice

This sanctions policy is updated regularly to reflect changes in international sanctions regimes and regulatory requirements. We reserve the right to update this policy at any time and will notify users of material changes.

Violations of this policy may result in immediate account termination, asset freezing, and reporting to relevant authorities. Criminal penalties may apply for willful sanctions violations.

Document Version: 2.3.0 | Last Updated: January 2024

This sanctions policy is reviewed monthly and updated immediately when new sanctions are imposed or existing sanctions are modified. Users are responsible for ensuring they comply with all applicable sanctions laws.