SANCTIONS SCREENING PROCEDURE

• Procedure Reference: _____________________________________________
• Version: _____________________________________________
• Effective Date: _____________________________________________
• Review Date: _____________________________________________
• Procedure Owner: _____________________________________________

1. Purpose

This Sanctions Screening Procedure (the "Procedure") sets out the mandatory steps to be followed by all Personnel engaged in trade facilitation, commercial transactions, or counterparty onboarding activities to ensure that the organisation does not engage in any transaction with a sanctioned person, entity, or jurisdiction, or one that would otherwise violate applicable trade sanctions or export control regimes.

2. Applicable Sanctions Regimes

• The following sanctions regimes are applicable to the organisation's activities and must be screened against for each new counterparty and on the periodic schedule set out in section 5:
• EU Consolidated List of Persons, Groups, and Entities Subject to EU Financial Sanctions (updated daily at eeas.europa.eu/topics/sanctions-policy)
• UK Office of Financial Sanctions Implementation (OFSI) Consolidated List (updated at gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets)
• US Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List) (updated at ofac.treas.gov)
• UN Security Council Consolidated Sanctions List (updated at un.org/securitycouncil/sanctions/information)
• Indian Ministry of Home Affairs (MHA) Designated Terrorist Entities List (where applicable)
• Any other applicable list as notified by the Compliance Officer for specific transactions or sectors.

3. Who Must Be Screened

• The following persons and entities must be screened for each new commercial relationship or transaction:
• The counterparty entity itself (full legal name and all known trading names);
• All known directors and officers of the counterparty;
• All known ultimate beneficial owners (UBOs) holding ten per cent (10%) or more of the shares or voting rights of the counterparty;
• Any agent, broker, or intermediary involved in the transaction;
• The end-user of any goods or services, where known;
• The country or jurisdiction of the counterparty and the destination country of goods or services;
• Any bank or financial institution involved in the payment chain, where known.

4. Step-by-Step Screening Process

Step 1 — Gather Counterparty Information

Before initiating screening, collect the following information on the counterparty: full legal name; registered country and address; registration or company number; names of directors, officers, and UBOs; nature of business; and the country of destination of any goods or services.

Step 2 — Conduct Screening

Using the organisation's approved screening tool (_____________ [insert tool name] or the official government list sources referenced in section 2), run a search of the counterparty's full legal name and all known aliases or trading names against each of the applicable sanctions lists. Record the search parameters, date, list version searched, and result for each list.

Step 3 — Assess Results

Clear Result: No match found on any applicable list. Record the result and proceed with the transaction. File the screening record with the transaction file.

Potential Match / Hit: A match or partial match is identified. Do not proceed with the transaction. Escalate immediately to the Compliance Officer with full details of the match. The Compliance Officer shall assess whether the match relates to the specific counterparty or is a false positive.

False Positive: The Compliance Officer determines that the match does not relate to the counterparty. Document the rationale in full, including the distinguishing factors (e.g. different country, different date of birth, different registration number). File the false positive determination with the screening record. The transaction may proceed.

Confirmed Hit: The Compliance Officer confirms that the counterparty is or may be a sanctioned person or entity. Do not proceed with the transaction. The Compliance Officer shall determine whether voluntary disclosure to the relevant regulatory authority is required and shall seek legal advice. The transaction is declined and the record filed.

Step 4 — Complete the Sanctions Screening Record

Complete the Sanctions Screening Record (Annex A to this Procedure) for every screening exercise, regardless of result. The Record shall be signed by the screener and countersigned by the Compliance Officer where a Hit or potential Hit was identified.

Step 5 — File and Retain

File the completed Sanctions Screening Record with the transaction file or counterparty onboarding file. Records must be retained for a minimum of five (5) years from the date of screening.

5. Periodic Re-Screening Schedule

In addition to onboarding screening, all active counterparties must be re-screened as follows:

Annually: All counterparties with whom the organisation has conducted a transaction in the preceding twelve (12) months.

Upon material change: Immediately upon becoming aware of any material change in the counterparty's ownership, management, jurisdiction, or business activities.

Upon list update: When a significant update to an applicable sanctions list affects a sector or jurisdiction relevant to the organisation's activities, the Compliance Officer may direct an immediate re-screen of all counterparties in that sector or jurisdiction.

Upon transaction escalation: Where a single transaction exceeds _____________ in value, an additional pre-execution screen shall be conducted regardless of the last screening date.

6. High-Risk Indicators Requiring Enhanced Screening

The following indicators shall trigger enhanced screening and mandatory Compliance Officer involvement before the transaction proceeds:

The counterparty is incorporated in, or the goods are destined for, a jurisdiction subject to comprehensive sanctions (including but not limited to: Iran, North Korea, Russia, Belarus, Syria, Cuba, or Sudan — subject to the applicable sanctions regime at the time of the transaction);

The counterparty is a government entity or state-owned enterprise;

The transaction involves goods or technology with dual-use, military, or proliferation-sensitive applications;

The counterparty is unwilling to provide information about its beneficial ownership or end-use of goods;

The payment routing involves a jurisdiction known to be used for sanctions evasion;

The counterparty has recently changed name, jurisdiction, or ownership structure without a clear commercial rationale.

7. Sanctions Screening Record — Annex A

• Complete one record per screening exercise. Retain with the transaction file.
• Screening Results:
• Doc 21 — Sanctions Screening Procedure — Neutral Template