Sanctions policy

1. Purpose and scope

This policy sets out how Jadenex complies with financial sanctions, trade sanctions and export control measures that apply to its business. It applies to every applicant, every account holder, every counterparty and every member of staff.

Jadenex applies the sanctions measures of the jurisdiction in which it is established and of any jurisdiction whose measures apply to a transaction, a currency or a counterparty involved in the service.

2. Screening

Screening is applied at the following points.

1. At application, before an account is opened.
2. On every update to a sanctions list, against the entire customer base.
3. On every deposit and withdrawal instruction, against the counterparty and, for a digital asset transfer, against the address and its exposure.
4. Periodically as part of ongoing due diligence, at a frequency determined by the risk rating of the account.

Screening covers the name of the person, known aliases, date of birth, nationality, country of residence, the internet protocol address from which the service is accessed and, for digital assets, the address and its counterparties as identified by blockchain analytics.

3. Restricted jurisdictions

Jadenex does not open an account for, and does not provide the service to, a person resident in a jurisdiction subject to comprehensive sanctions, or a person located in such a jurisdiction at the time of access.

The list of jurisdictions Jadenex serves is maintained by the compliance team and is updated as measures change. An application from outside that list is refused. Where an existing account holder moves to a jurisdiction that is no longer served, the account is restricted to withdrawal only to the extent that the law permits a withdrawal to be made.

Access from a jurisdiction that is not served, including access through a tool that conceals location, is a breach of the terms of service and may result in the account being blocked.

4. Handling a match

Where screening returns a potential match, the following steps are taken.

1. The transaction or application is stopped immediately and no asset is released.
2. The match is reviewed against identifying information to establish whether it is a true match or a false positive.
3. A false positive is recorded with the reasons and the matter proceeds.
4. A true match results in the account being blocked, the assets being frozen to the extent required by the applicable measure, and a report being made to the competent authority within the period required.
5. No information about the report is disclosed to the person concerned or to any third party.

5. Frozen assets

Where an asset is frozen under a sanctions measure, it is held and is not released except under a licence granted by the competent authority or where the measure ceases to apply. Jadenex does not deal in a frozen asset and does not permit a trade against it.

6. Evasion and circumvention

The following conduct is prohibited and results in the account being closed and reported.

• Concealing the location of the account holder or the source of a transfer.
• Using a third party to hold or move assets on behalf of a sanctioned person.
• Structuring transfers to avoid a screening threshold.
• Providing false identification or address information at any stage.

7. Governance, training and records

The compliance function owns this policy and has authority to block an account, to freeze an asset and to make a report without reference to the commercial function.

Staff complete sanctions training on joining and at least annually thereafter.

Screening results, review decisions, blocking actions and reports are recorded and retained for at least five years, and for longer where the competent authority requires it.