Effective Date: 01.03.2025

1. Purpose

This policy outlines our approach to ensuring compliance with applicable international sanctions regimes and restrictive measures. URIGHTCOMPANY FINANCE LIMITED (“we”, “us”, “our”) is committed to preventing transactions with sanctioned persons, entities, and jurisdictions.

2. Scope

Applies to:
– All clients and beneficial owners
– All transactions (fiat and crypto)
– All employees, contractors, and partners
– All jurisdictions where we operate

3. Applicable Sanctions Lists

We screen and restrict individuals and entities listed on:
– United Nations Sanctions List
– Office of Foreign Assets Control (OFAC) – SDN List
– European Union Sanctions List
– Canada’s Consolidated Sanctions List (GAC)
– Other relevant local and global sanctions lists

4. Client Screening Procedures

All clients and their ultimate beneficial owners (UBOs) are screened at onboarding and on an ongoing basis.
Screening occurs using third-party tools and manual checks.
Clients flagged as sanctioned or linked to sanctioned entities are automatically rejected or blocked.
Politically Exposed Persons (PEPs) are subject to enhanced due diligence (EDD).

5. Transaction Screening

All transactions are monitored and screened for potential sanctions violations.
Risk-based filters and rules are applied depending on transaction type, currency, and destination.
Transactions involving high-risk jurisdictions or flagged parties are escalated to Compliance.

6. High-Risk Jurisdictions

We prohibit or restrict activity involving jurisdictions that are:
– Subject to comprehensive international sanctions
– Listed as high-risk by FATF
– Deemed uncooperative in AML/CTF matters

7. Actions Upon Detection

If a sanctioned party or transaction is identified:
– Funds are frozen or withheld, where legally required
– The case is escalated to the Compliance Officer
– A report may be submitted to FINTRAC or other competent authorities

8. Training

All employees receive training on:
– Recognizing sanctioned entities and countries
– Proper procedures for escalation
– Legal obligations under Canadian and international law

Training is mandatory at hiring and refreshed annually.

9. Record Keeping

All sanctions screening logs and compliance decisions are documented and retained for 5 years.

10. Responsibilities

The Compliance Officer is responsible for:
– Maintaining up-to-date sanctions lists
– Overseeing screening tools and rules
– Reporting to FINTRAC and regulators as required

11. Policy Review

This policy is reviewed at least annually or upon changes in relevant sanctions regulations.

Contact Compliance Officer: [email protected]