Sanctions Compliance Policy

This Sanctions Compliance Policy establishes Kuraye's framework for screening customers, transactions, and business relationships against applicable sanctions lists. The policy covers UK OFSI, UN, EU, and US OFAC requirements, screening frequency, transaction screening, customer screening, business screening, ownership screening, watchlist management, false positive handling, escalation procedures, frozen transaction management, and reporting obligations.

This policy applies to all customers, counterparties, transactions, and business relationships, including individual customers and consumers, enterprise clients and corporate entities, marketplace sellers and service providers, directors, officers, and beneficial owners, payment transactions and settlement flows, and business partnerships and agency relationships.

Kuraye's sanctions compliance programme is designed in accordance with UK Office of Financial Sanctions Implementation (OFSI) requirements, United Nations Security Council sanctions resolutions, European Union sanctions regulations, US Office of Foreign Assets Control (OFAC) regulations where applicable, and applicable jurisdictional sanctions laws.

Kuraye screens against the UK OFSI Consolidated List, UN Security Council sanctions list, EU sanctions list, US OFAC Specially Designated Nationals (SDN) List, US OFAC Sectoral Sanctions Identifications (SSI) List, and other applicable jurisdictional sanctions lists. Screening covers full legal name and known aliases, date of birth, place of birth, nationality, address and registered address, company registration numbers, tax identification numbers, known beneficial owners and directors, and IP addresses and geographic indicators.

All prospective customers are screened at onboarding against all applicable sanctions lists before account activation or first transaction. Screened customers are rescreened minimum every 30 days, immediately upon sanctions list updates, prior to high-value transactions, and when risk indicators change. All transactions are screened before processing and monitored during processing for real-time sanctions list updates, changes to counterparty status, and geographic routing through sanctioned jurisdictions.

All corporate entities are screened by registered company name and trading names, company registration number, jurisdiction of incorporation, registered and trading addresses, nature of business activity, directors and officers, and known beneficial owners. Marketplace sellers are screened at application for seller status, prior to publication, at defined periodic intervals, immediately upon sanctions list updates, and before significant product or service listings.

Screening lists are updated automatically where technically feasible, with manual updates applied within 24 hours of publication. List providers are selected for reliability and comprehensiveness, and list coverage is audited quarterly. False positives are managed through tuning of screening rules and thresholds, manual review and classification, feedback loops to screening providers, and periodic false-positive rate monitoring.

Escalate to Compliance Officer within 1 hour for confirmed sanctions match, transaction with sanctioned counterparty, account opened or transacted by sanctioned party, or evasion of sanctions controls detected. Escalate within 24 hours for potential match requiring manual review, high-risk jurisdiction routing, structuring or evasion indicators, or confirmed sanctions breach. The Compliance Officer or senior management may freeze transactions or accounts where sanctions match is confirmed or probable pending investigation.

OFSI is notified of confirmed sanctions breaches within the statutory timeframe. The National Crime Agency is notified where money laundering or terrorist financing indicators accompany sanctions breaches. Law enforcement and regulatory bodies are notified where required. Compliance Officer reports sanctions matters to senior management monthly, with material sanctions breaches reported to Board immediately.

For inquiries regarding sanctions screening, frozen transactions, or sanctions compliance, please contact our compliance desk at info@aakuraye.tech.