Sanctions Compliance Policy

1. Regulatory Framework

Our sanctions compliance programme is designed to satisfy the requirements of:

• Canada: Special Economic Measures Act (SEMA), Justice for Victims of Corrupt Foreign Officials Act (JVCFOA), United Nations Act, and regulations made under these statutes
• United States: Sanctions programmes administered by the Office of Foreign Assets Control (OFAC), including the International Emergency Economic Powers Act (IEEPA) and associated Executive Orders
• United Nations: UN Security Council sanctions resolutions
• European Union: EU sanctions and restrictive measures adopted by the European Council
• International: Financial Action Task Force (FATF) high-risk and non-cooperative jurisdictions designations

2. Sanctions Lists Screened

Anton screens all merchants, beneficial owners, payees, and transactions against the following sanctions lists:

List data is downloaded from authoritative government sources and cached locally. If a source is temporarily unavailable, screening continues against the most recently cached version. List freshness metadata is logged for audit purposes.

3. Screening Architecture

Anton operates a multi-layer sanctions screening architecture to ensure that no transaction bypasses sanctions controls:

• Primary screening: Real-time sanctions evaluation integrated into the transaction risk scoring engine, using directly sourced government list data
• Secondary screening: A separate compliance worker gates payout state transitions, backed by Persona's sanctions screening capabilities as the production implementation
• Rail partner screening: Payment rail partners with their own beneficiary sanctions screening perform independent checks, providing an additional layer of protection

If the primary screening engine is unavailable, the secondary layer (backed by Persona) serves as the primary screening authority, ensuring no transaction is processed without sanctions screening.

4. Screening Trigger Points

Sanctions screening occurs at the following points in the lifecycle:

Weekly batch rescreening ensures that entities added to sanctions lists between point-in-time screening events are identified within a maximum of seven days.

5. Name Matching

Our sanctions screening name matching pipeline employs multiple techniques to minimise both false negatives and false positives:

• Unicode normalisation, diacritics stripping, and transliteration (Arabic/Cyrillic to Latin)
• Name component decomposition (first, middle, last, title, suffix)
• Phonetic encoding for phonetic matching
• Token matching to handle name reordering
• Fuzzy string similarity scoring

Matches above the confidence threshold are either hard-blocked immediately (for SDN, UN SC, and CCASL matches) or routed to the compliance review queue for human investigation. All screening results, including non-matches, are logged for audit purposes.

6. Prohibited Countries and Jurisdictions

Anton enforces sanctions at both the infrastructure and application layers:

Hard-Blocked Countries

Traffic from the following OFAC-sanctioned countries is blocked at the network edge before reaching any application:

• North Korea (DPRK)
• Iran
• Syria
• Cuba

Payout transactions destined for FATF black-listed jurisdictions (North Korea, Iran, Myanmar) are hard-blocked at the application layer with immediate rejection.

Rate-Limited Jurisdictions

High-risk jurisdictions are subject to stricter rate limiting at the network edge: Belarus, Myanmar, South Sudan, Sudan, Somalia, Yemen, Zimbabwe, Venezuela, Russia, and Afghanistan.

Payout transactions to FATF grey-listed jurisdictions are subject to elevated risk scoring and may trigger enhanced due diligence.

Note: Crimea (UA-43) is not available in GeoIP databases for infrastructure-level blocking. Crimea sanctions enforcement is handled at the application layer through beneficiary address validation in the payout submission flow.

7. Match Handling and Disposition

When a potential sanctions match is identified, the following process applies:

• Confirmed hit: The transaction is automatically blocked and the associated account is flagged. Funds are frozen as required by law. The Compliance Officer is notified immediately.
• Possible hit: The transaction is held and routed to the compliance review queue for human investigation. A compliance officer reviews the match details and records a decision.
• Clear: The transaction proceeds to the next stage of processing.

All screening decisions are recorded in the immutable audit trail with the actor, timestamp, and decision rationale. Confirmed false positives are documented and may be added to an exclusion list to prevent repeated reviews, subject to quarterly review by the Compliance Officer.

8. Ministerial Directives

Under PCMLTFA Part 1.1, the Minister of Finance may issue directives requiring reporting entities to take specified measures with respect to designated foreign jurisdictions or entities. Anton monitors for the issuance of new ministerial directives through FINTRAC communications and the Canada Gazette, and implements required restrictions within the specified timeframe.

The Compliance Officer reviews active ministerial directives quarterly and upon notification of new or amended directives.

9. Travel Rule Compliance

In accordance with FATF Recommendation 16, Anton ensures that originator and beneficiary information accompanies all outbound payout transactions, as required by PCMLTFA electronic funds transfer regulations (Canada) and the BSA/FinCEN Funds Travel Rule (United States).

For fiat corridors, Travel Rule information is transmitted through SWIFT, SEPA, and domestic payment rail messaging standards. For virtual asset corridors, a dedicated Travel Rule compliance solution will be implemented and tested before any virtual asset payout corridor is activated.

10. Reporting

Anton complies with all applicable sanctions reporting requirements, including:

• Terrorist Property Reports (TPR): Filed immediately with FINTRAC, the RCMP, and CSIS upon knowledge or suspicion of terrorist property. Associated funds are frozen immediately.
• OFAC Blocked Property Reports: Filed within 10 business days of blocking a transaction involving a sanctioned party
• Annual reports of blocked property as required by OFAC

All sanctions-related reports and supporting documentation are retained for a minimum of seven years.

11. Prohibited Activities

Anton strictly prohibits:

• Processing transactions for individuals or entities on applicable sanctions lists
• Processing transactions involving comprehensively sanctioned countries or regions
• Facilitating transactions designed to evade sanctions
• Providing services to sanctioned parties, directly or indirectly
• Circumventing sanctions through intermediaries, shell entities, or layered transactions

Violations of this policy may result in disciplinary action, account termination, referral to law enforcement, and personal liability under applicable law. Sanctions violations carry severe civil and criminal penalties.

12. Policy Updates

This policy is reviewed at least annually, upon changes to applicable sanctions programmes, and following material compliance incidents. Sanctions list updates are monitored and applied daily. Material policy changes are approved by the board of directors.

13. Contact

For questions about our sanctions compliance procedures, please contact:

Anton Payments, Inc.
Compliance Department
Email: compliance@antonpayments.com