Sanctions Compliance Policy

1. Introduction

1.1. As an international business, Banuba and all its subsidiaries (collectively “Banuba Group”) is committed to carrying on its activities in accordance with the highest ethical standards. This commitment includes complying with all economic sanctions laws, regulations or restrictive measures to which it is subject.
1.2. This Sanctions Compliance Policy (“Policy”) applies to all legal entities, directors, officers, employees, contractors and other third parties acting on behalf of Banuba Group. Banuba Group will maintain effective measures to ensure compliance with and awareness of its Sanctions-related obligations.

2. Sanctions

2.1. Sanctions are restrictive measures applicable to certain countries, governments, groups, or persons. They are used as a foreign policy tool with the primary aim of bringing about a change in policy or conduct by depriving the sanctioned party of economic or other benefits.
2.2. Sanctions can be enacted by governments (such as the government of the United States or the United Kingdom), international organisations (such as the United Nations) and supranational bodies (such as the European Union):
2.2.1. E.U. Sanctions apply to:
2.2.1.1. E.U. entities and E.U. nationals in relation to anything they do anywhere in the world – even if an E.U. national is employed by a non-E.U. company;
2.2.1.2. non-E.U. entities and non-E.U. national employees in relation to anything they do in the E.U. and any business conducted wholly or partly in the E.U.
2.2.2. U.S. Sanctions apply to: 
2.2.2.1. U.S. entities and their overseas branches (and, for certain sanctions, non-U.S. subsidiaries of U.S. entities) in relation to anything they do anywhere in the world;
2.2.2.2. U.S. citizens and permanent resident aliens (i.e. “green card” holders) in relation to anything they do anywhere in the world;
2.2.2.3. non-U.S. entities and non-U.S. nationals in relation to anything they do in the U.S. and any business conducted wholly or partly in the United States.
2.2.3. U.K. Sanctions apply to:
2.2.3.1. U.K. entities and U.K. nationals in relation to anything they do anywhere in the world – even if a U.K. national is employed by a non-UK company;
2.2.3.2. non-U.K. entities and non-U.K. national employees in relation to anything they do in the U.K. and any business conducted wholly or partly in the U.K.
2.2.4. U.N. Sanctions apply to:
2.2.4.1. individuals, entities and States designated by the U.N. Security Council resolutions.

3. Compliance with Sanctions

3.1. Banuba Group complies with the requirements of the U.S., U.K., U.N. and E.U. Sanctions regimes (whenever this apply to its operations) wherever it operates, and will not undertake any business that would breach those Sanctions regimes.
3.2. Banuba Group will also comply with other Sanctions regimes whenever they apply to particular operations and will not undertake any business that would breach those Sanctions regimes.
3.3. Before engaging in any commercial relationship or transaction, Banuba Group ensures that these relationships and transactions comply with applicable U.S., U.K., U.N. and E.U. Sanctions regimes, by screening those individuals or entities against the Specially Designated Nationals list and other relevant Sanctions lists. The Company shall also screen its transactions as to potential violations on country specific sanctions.
3.4. Banuba Group do not participate in transactions or engage in conduct designed or intended to evade or facilitate a breach of applicable Sanctions regimes.
3.5. If you are in any doubt or have any questions or concerns regarding applicability of the Policy, please contact the Legal Department at: legal@banuba.com before proceeding further.

4. Red flags

4.1.All Banuba Group employees and contractors shall look for potential red flags or suspicions that may indicate sanctions compliance concerns and immediately notify Legal Department at: legal@banuba.com regarding such concerns.
4.2. Examples of potential red flags include:
4.2.1. The customer does not provide clear information regarding its commercial status and legal address;
4.2.2. The customer provides information which can not be verified;
4.2.3. Unusual invoicing requests;
4.2.4. Unusual payment method proposed (credit cards, cryptocurrencies, etc.);
4.2.5. Usage of sanctioned banks to make a payment;
4.2.6. Usage of suspicious electronic money institutions to make a payment;
4.2.7. Any possible connections with Politically Exposed Persons (“PEPs”);
4.2.8. Any suspicion or evidence to suggest the possible involvement of Sanctioned individuals or entities;
4.2.9. Request to sublicense the technology to third parties without provision of clear information in regard to their identity.
4.3. Course of actions in case of red flags:
4.3.1. If any employee, contractor or other third party acting on behalf of Banuba Group notices the potential red flag either before starting any relationship with a third party or after its start, it shall immediately notify Legal Department regarding the potential red flag;
4.3.2. Upon receipt of such information Legal Department initiates KYC procedure in respect of the third party by requesting the list of documents which it considers necessary to eliminate the risks of potential red flags while conducting third party screening through the Sanctions lists;
4.3.3. If a third party seriously delays with the provision of the requested documents, Banuba Group will terminate any communication with such a client and treat such a delay as a failed KYC procedure;
4.3.4. If as a result of KYC check it turns out that the third party, its directors, members or its ultimate beneficial owners are subject to any Sanctions regimes, than Banuba Group will immediately terminate any communication and relationship with such third party.

5. Risks of non-compliance with Sanctions

5.1. Banuba Group has a zero-tolerance approach to intentional violations of this Policy or applicable Sanctions regimes. If an employee fails to comply with this Policy, then he/she may be subject to disciplinary action that may include dismissal from employment. Violations of Sanctions can also have legal consequences for individuals involved, including severe monetary fines and imprisonment.
5.2. Banuba Group will terminate relationship with any third party (including terminating all contracts and agreements in force) by means of written notice to the third party with immediate effect if it becomes aware that the third party is in violation of this Policy or becomes subject to the U.S., U.K., U.N. and E.U. Sanctions regimes.

6. Updates and Review

Last update: 06 December, 2022