Sanctions Policy

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 and 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 and 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 and 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 and 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 and Client Alerts or Transactions

Airacom will promptly and thoroughly investigate all customer and 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.

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