SANCTIONS COMPLIANCE POLICY
Last Updated: December 9, 2024
1. INTRODUCTION
Aegis Vault Ltd. (“Company,” “we,” “our,” or “us”), a company incorporated under the laws of the British Virgin Islands with registration number 2163500, is committed to complying with all applicable sanctions laws and regulations. This Sanctions Compliance Policy (“Policy”) outlines our approach to ensuring adherence to international sanctions regimes.
2. JURISDICTIONAL FRAMEWORK
2.1 Applicable Sanctions Regimes
We comply with sanctions imposed by:
- United Nations Security Council
- British Virgin Islands
- European Union
- UK Financial Sanctions
- Other applicable international authorities
2.2 Jurisdictional Restrictions
Our services are not available to:
- Residents of the United States of America
- Citizens of the United States of America
- Persons located in the United States of America
- Entities incorporated or organized under US laws
- Persons subject to US jurisdiction
- Sanctioned individuals or entities
- Residents of comprehensively sanctioned countries
3. SANCTIONS COMPLIANCE PROGRAM
3.1 Core Elements
Our program includes:
- Risk assessment
- Internal controls
- Testing and audit
- Training
- Management commitment
3.2 Screening Procedures
We implement:
- Customer screening
- Transaction monitoring
- Ongoing due diligence
- Risk-based approach
- Regular updates
4. PROHIBITED ACTIVITIES
4.1 General Prohibitions
We prohibit:
- Transactions with sanctioned parties
- Evasion of sanctions
- Facilitation of prohibited activities
- Dealings with restricted countries
4.2 Specific Restrictions
Including but not limited to:
- Sanctioned cryptocurrency addresses
- Designated persons and entities
- Restricted territories
- Prohibited transactions
5. DUE DILIGENCE
5.1 Customer Due Diligence
We conduct:
- Identity verification
- Sanctions screening
- Risk assessment
- Ongoing monitoring
5.2 Enhanced Due Diligence
Applied to:
- High-risk customers
- Complex structures
- High-value transactions
- Suspicious activities
6. MONITORING AND SCREENING
6.1 Transaction Monitoring
We monitor:
- All transactions
- Wallet addresses
- User behavior
- Suspicious patterns
6.2 Screening Tools
We utilize:
- Automated screening systems
- Blockchain analytics
- Risk scoring
- Alert management
7. REPORTING AND DOCUMENTATION
7.1 Internal Reporting
Requirements for:
- Suspicious activity
- Potential violations
- Compliance concerns
- Risk indicators
7.2 External Reporting
Reporting to:
- Regulatory authorities
- Law enforcement
- Financial Intelligence Unit
- Other relevant bodies
8. TRAINING AND AWARENESS
8.1 Staff Training
Regular training on:
- Sanctions requirements
- Compliance procedures
- Red flags
- Reporting obligations
8.2 Updates and Refresher
Provided for:
- New regulations
- Policy changes
- Emerging risks
- Best practices
9. ENFORCEMENT AND PENALTIES
9.1 Internal Enforcement
Consequences include:
- Disciplinary action
- Contract termination
- Legal action
- Financial penalties
9.2 Regulatory Enforcement
Understanding of:
- Criminal penalties
- Civil fines
- Regulatory actions
- Reputational impact
10. RECORD KEEPING
10.1 Documentation Requirements
Maintaining records of:
- Screening results
- Due diligence
- Investigations
- Training completion
10.2 Retention Period
Records kept for:
- Minimum 5 years
- Extended if required
- Regulatory compliance
- Audit purposes