Anton Payments

Legal

Sanctions Compliance Policy

Last updated: January 2024

1. Introduction

Anton Payments, Inc. is committed to full compliance with all applicable economic sanctions, trade embargoes, and restrictive measures imposed by the United States, United Nations, European Union, United Kingdom, and other jurisdictions where we operate. This Sanctions Compliance Policy outlines our procedures for screening, identifying, and preventing transactions involving sanctioned parties or countries.

2. Legal and Regulatory Framework

Our sanctions compliance program is designed to comply with:

  • United States: Office of Foreign Assets Control (OFAC) sanctions programs, including but not limited to:
    • Specially Designated Nationals (SDN) List
    • Sectoral Sanctions Identifications (SSI) List
    • Non-SDN Menu-Based Sanctions (NS-MBS) List
    • Foreign Sanctions Evaders (FSE) List
    • Palestinian Legislative Council (NS-PLC) List
  • United Nations: UN Security Council sanctions resolutions
  • European Union: EU sanctions and restrictive measures
  • United Kingdom: UK sanctions regimes
  • Other Jurisdictions: Applicable sanctions in all countries where we operate

3. Sanctions Screening

We conduct comprehensive sanctions screening at multiple stages:

3.1 Customer Onboarding

All customers are screened against sanctions lists during the onboarding process, including:

  • Individual customers: Name, date of birth, nationality
  • Business customers: Business name, beneficial owners, authorized representatives
  • Geographic screening: Country of residence, incorporation, or operation

3.2 Ongoing Screening

We conduct ongoing screening of:

  • All transactions before processing
  • Customer information updates and changes
  • Payees and payment recipients
  • Counterparties and business partners
  • Regular batch screening of existing customers against updated sanctions lists

3.3 Screening Technology

We employ automated screening systems that:

  • Screen against multiple sanctions lists simultaneously
  • Use fuzzy matching and name variant algorithms
  • Flag potential matches for manual review
  • Maintain audit trails of all screening activities
  • Update sanctions lists regularly (typically daily or real-time)

4. Prohibited Activities

We strictly prohibit:

  • Processing transactions for individuals or entities on sanctions lists
  • Processing transactions involving sanctioned countries or regions
  • Facilitating transactions that would violate sanctions
  • Providing services to sanctioned parties, directly or indirectly
  • Circumventing or evading sanctions through intermediaries or third parties

5. Sanctioned Countries and Regions

We do not process transactions involving countries or regions subject to comprehensive sanctions, including but not limited to:

  • Countries subject to comprehensive OFAC sanctions (e.g., Cuba, Iran, North Korea, Syria, Crimea region of Ukraine)
  • Countries subject to EU comprehensive sanctions
  • Other jurisdictions subject to comprehensive sanctions by applicable authorities

Note: Sanctions lists and restricted countries are subject to change. We continuously monitor and update our restrictions based on current sanctions programs.

6. Match Resolution and Investigation

When a potential sanctions match is identified:

  1. Initial Review: Automated system flags potential match
  2. Investigation: Compliance team reviews match details
  3. False Positive Resolution: If match is determined to be a false positive, transaction may proceed
  4. True Match: If confirmed match, transaction is blocked and reported
  5. Documentation: All matches and resolutions are documented

7. Blocking and Rejecting Transactions

When a sanctions match is confirmed:

  • Transaction Blocking: Transaction is immediately blocked
  • Account Action: Account may be suspended or terminated
  • Reporting: Blocked transaction is reported to OFAC or relevant authority within required timeframes
  • Asset Freezing: Funds may be frozen as required by law
  • Notification: Customer is notified of the block (where legally permissible)

8. Reporting Requirements

We comply with all reporting requirements for sanctions-related activities, including:

  • OFAC Blocked Property Reports (within 10 business days)
  • Annual reports of blocked property
  • Reports to other relevant authorities as required
  • Maintenance of records for regulatory examination

9. Training and Awareness

All employees receive training on sanctions compliance, including:

  • Overview of applicable sanctions programs
  • Recognition of sanctions red flags
  • Screening procedures and match resolution
  • Blocking and reporting requirements
  • Consequences of sanctions violations

10. Third-Party Relationships

We conduct sanctions screening on:

  • Vendors and service providers
  • Payment processors and financial institutions
  • Business partners and referral partners
  • Any third party with whom we have a business relationship

11. Record Keeping

We maintain comprehensive records of all sanctions-related activities, including:

  • Screening results and match investigations
  • Blocked transactions and property
  • Reports filed with regulatory authorities
  • Training records
  • Policy updates and program changes

Records are retained in accordance with applicable requirements (typically 5 years or longer).

12. Updates to This Policy

This Sanctions Compliance Policy is reviewed and updated regularly to reflect changes in sanctions programs, laws, and regulations. We monitor sanctions updates daily and adjust our procedures accordingly.

13. Contact

For questions about our sanctions compliance procedures, please contact:

Anton Payments, Inc.
Chief Compliance Officer
Email: [email protected]
Sanctions Inquiries: [email protected]