Airacom Limited’s Global Sanctions Policy
Policy Mission Statement:
Airacom is committed to complying with all applicable sanctions laws and regulations. This policy sets out the minimum standards with which all Airacom Worldwide Group entities must comply.
1.0 Purpose
The purpose of Airacom’s Global Sanctions Policy is to establish a comprehensive framework for complying with all applicable sanctions laws and regulations. This policy applies to all Airacom Worldwide Group entities and their subsidiaries.
2.0 Scope
This policy covers all aspects of Airacom’s business, including but not limited to:
Customer/client screening
Transaction screening
Business activity with individuals or entities named on a sanctions list
Business activity involving countries or territories subject to comprehensive sanctions
Business activity involving countries or persons subject to more selective or targeted sanctions programs
Investigation of customer/client alerts or transactions that are stopped in Airacom’s screening systems
Blocking or rejecting transactions
Reporting breaches of sanctions laws
3.0 Definitions
For the purposes of this policy, the following definitions apply:
Sanctions laws and regulations: Any laws, regulations, or orders issued by any government or international organization that prohibit or restrict certain business activities with individuals, entities, or countries.
Sanctions list: A list of individuals, entities, or countries that are subject to sanctions laws and regulations.
Comprehensive sanctions: Sanctions that are so broad that they effectively prohibit all business activity with a particular country.
Selective sanctions: Sanctions that are targeted at specific individuals, entities, or industries.
Due diligence: The process of taking reasonable steps to verify the identity and legitimacy of a customer/client or transaction.
Risk appetite: The level of risk that Airacom is willing to accept in its business operations.
4.0 Compliance Obligations
Airacom is committed to complying with all applicable sanctions laws and regulations. This includes:
Screening all customers/clients and transactions against the relevant sanctions lists.
Prohibiting business activity with individuals or entities named on a sanctions list.
Restricting certain business activity involving countries or persons subject to more selective or targeted sanctions programs.
Investigating all customer/client alerts or transactions that are stopped in Airacom’s screening systems.
Blocking or rejecting transactions that Airacom is required to do so under applicable sanctions laws or regulations.
Reporting breaches of sanctions laws to the relevant regulatory authority.
5.0 Record Keeping
Airacom will maintain records of its compliance with this policy, including but not limited to:
Sanctions screening results
Due diligence documentation
Transaction records
Reports to regulatory authorities
6.0 Training
Airacom will provide training to its employees on sanctions compliance. This training will cover the following topics:
The scope of sanctions laws and regulations
The identification of potential sanctions risks
The steps to take to mitigate sanctions risks
7.0 Enforcement
Airacom will take appropriate disciplinary action against any employee who violates this policy. Airacom will review and update this policy as needed to reflect sanctions laws and regulations changes.
8.0 Customer/Client Screening
Airacom will screen all customers/clients against the relevant sanctions lists before commencing or continuing any customer relationship. This screening will include checking the customer/client’s name, address, and other relevant information against the sanctions lists.
9.0 Transaction Screening
Airacom will screen all transactions against the relevant sanctions lists before executing any transaction. This screening will include checking the parties to the transaction, the amount of the transaction, and the destination of the transaction.
10.0 Business Activity with Individuals or Entities Named on a Sanctions List
Airacom will not engage in any business activity with individuals or entities named on a sanctions list. This includes but not limited to:
Opening or maintaining a customer account
Providing products or services
Facilitating transactions
11.0 Business Activity Involving Countries or Territories Subject to Comprehensive Sanctions
Airacom will not engage in any business activity involving countries or territories subject to comprehensive sanctions. This includes but not limited to:
Exporting or importing goods or services
Making investments
Providing financial services
12.0 Business Activity Involving Countries or Persons Subject to More Selective or Targeted Sanctions Programs
Airacom will comply with all applicable restrictions on business activity involving countries or persons subject to more selective or targeted sanctions programs. This includes but not limited to:
Obtaining required licenses or permits
Implementing appropriate due diligence procedures
Reporting certain transactions to the relevant government or international organization
11.0 Investigation of Customer/Client Alerts or Transactions
Airacom will promptly and thoroughly investigate all customer/client alerts or transactions flagged by its screening systems or otherwise identified as potential sanctions risks.
Airacom will also maintain a record of all customer/client alerts or transactions flagged by its screening systems, even if no further investigation is necessary. This record will include the date and time of the alert, the reason for the alert, and the action taken.