Sanctions Policy

1.1Nexone shall apply the principles of "Policy Statement" in a manner consistent with clause 1. Sub-clause 1.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

1.2For the purposes of clause 1 (Policy Statement), the customer acknowledges and agrees that any obligation described in sub-clause 1.2 is a material term of this document and non-compliance may result in restrictions on the account.

1.3Sub-clause 1.3 clarifies the scope of clause 1 (Policy Statement) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

1.4Where circumstances require an exception to clause 1 (Policy Statement), sub-clause 1.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

2.1Nexone shall apply the principles of "Regulatory Sources" in a manner consistent with clause 2. Sub-clause 2.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

2.2For the purposes of clause 2 (Regulatory Sources), the customer acknowledges and agrees that any obligation described in sub-clause 2.2 is a material term of this document and non-compliance may result in restrictions on the account.

2.3Sub-clause 2.3 clarifies the scope of clause 2 (Regulatory Sources) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

2.4Where circumstances require an exception to clause 2 (Regulatory Sources), sub-clause 2.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

3.1Nexone shall apply the principles of "Sanctions Lists Screened" in a manner consistent with clause 3. Sub-clause 3.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

3.2For the purposes of clause 3 (Sanctions Lists Screened), the customer acknowledges and agrees that any obligation described in sub-clause 3.2 is a material term of this document and non-compliance may result in restrictions on the account.

3.3Sub-clause 3.3 clarifies the scope of clause 3 (Sanctions Lists Screened) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

3.4Where circumstances require an exception to clause 3 (Sanctions Lists Screened), sub-clause 3.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

4.1Nexone shall apply the principles of "Blocked Jurisdictions" in a manner consistent with clause 4. Sub-clause 4.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

4.2For the purposes of clause 4 (Blocked Jurisdictions), the customer acknowledges and agrees that any obligation described in sub-clause 4.2 is a material term of this document and non-compliance may result in restrictions on the account.

4.3Sub-clause 4.3 clarifies the scope of clause 4 (Blocked Jurisdictions) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

4.4Where circumstances require an exception to clause 4 (Blocked Jurisdictions), sub-clause 4.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

5.1Nexone shall apply the principles of "Restricted Jurisdictions" in a manner consistent with clause 5. Sub-clause 5.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

5.2For the purposes of clause 5 (Restricted Jurisdictions), the customer acknowledges and agrees that any obligation described in sub-clause 5.2 is a material term of this document and non-compliance may result in restrictions on the account.

5.3Sub-clause 5.3 clarifies the scope of clause 5 (Restricted Jurisdictions) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

5.4Where circumstances require an exception to clause 5 (Restricted Jurisdictions), sub-clause 5.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

6.1Nexone shall apply the principles of "Screening at Onboarding" in a manner consistent with clause 6. Sub-clause 6.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

6.2For the purposes of clause 6 (Screening at Onboarding), the customer acknowledges and agrees that any obligation described in sub-clause 6.2 is a material term of this document and non-compliance may result in restrictions on the account.

6.3Sub-clause 6.3 clarifies the scope of clause 6 (Screening at Onboarding) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

6.4Where circumstances require an exception to clause 6 (Screening at Onboarding), sub-clause 6.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

7.1Nexone shall apply the principles of "Ongoing Screening" in a manner consistent with clause 7. Sub-clause 7.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

7.2For the purposes of clause 7 (Ongoing Screening), the customer acknowledges and agrees that any obligation described in sub-clause 7.2 is a material term of this document and non-compliance may result in restrictions on the account.

7.3Sub-clause 7.3 clarifies the scope of clause 7 (Ongoing Screening) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

7.4Where circumstances require an exception to clause 7 (Ongoing Screening), sub-clause 7.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

8.1Nexone shall apply the principles of "Screening of Beneficial Owners" in a manner consistent with clause 8. Sub-clause 8.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

8.2For the purposes of clause 8 (Screening of Beneficial Owners), the customer acknowledges and agrees that any obligation described in sub-clause 8.2 is a material term of this document and non-compliance may result in restrictions on the account.

8.3Sub-clause 8.3 clarifies the scope of clause 8 (Screening of Beneficial Owners) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

8.4Where circumstances require an exception to clause 8 (Screening of Beneficial Owners), sub-clause 8.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

9.1Nexone shall apply the principles of "Screening of Counterparties" in a manner consistent with clause 9. Sub-clause 9.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

9.2For the purposes of clause 9 (Screening of Counterparties), the customer acknowledges and agrees that any obligation described in sub-clause 9.2 is a material term of this document and non-compliance may result in restrictions on the account.

9.3Sub-clause 9.3 clarifies the scope of clause 9 (Screening of Counterparties) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

9.4Where circumstances require an exception to clause 9 (Screening of Counterparties), sub-clause 9.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

10.1Nexone shall apply the principles of "Transaction-Level Screening" in a manner consistent with clause 10. Sub-clause 10.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

10.2For the purposes of clause 10 (Transaction-Level Screening), the customer acknowledges and agrees that any obligation described in sub-clause 10.2 is a material term of this document and non-compliance may result in restrictions on the account.

10.3Sub-clause 10.3 clarifies the scope of clause 10 (Transaction-Level Screening) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

10.4Where circumstances require an exception to clause 10 (Transaction-Level Screening), sub-clause 10.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

11.1Nexone shall apply the principles of "IP and Geolocation Controls" in a manner consistent with clause 11. Sub-clause 11.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

11.2For the purposes of clause 11 (IP and Geolocation Controls), the customer acknowledges and agrees that any obligation described in sub-clause 11.2 is a material term of this document and non-compliance may result in restrictions on the account.

11.3Sub-clause 11.3 clarifies the scope of clause 11 (IP and Geolocation Controls) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

11.4Where circumstances require an exception to clause 11 (IP and Geolocation Controls), sub-clause 11.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

12.1Nexone shall apply the principles of "Device Fingerprinting" in a manner consistent with clause 12. Sub-clause 12.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

12.2For the purposes of clause 12 (Device Fingerprinting), the customer acknowledges and agrees that any obligation described in sub-clause 12.2 is a material term of this document and non-compliance may result in restrictions on the account.

12.3Sub-clause 12.3 clarifies the scope of clause 12 (Device Fingerprinting) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

12.4Where circumstances require an exception to clause 12 (Device Fingerprinting), sub-clause 12.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

13.1Nexone shall apply the principles of "Sanctions Hit Escalation" in a manner consistent with clause 13. Sub-clause 13.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

13.2For the purposes of clause 13 (Sanctions Hit Escalation), the customer acknowledges and agrees that any obligation described in sub-clause 13.2 is a material term of this document and non-compliance may result in restrictions on the account.

13.3Sub-clause 13.3 clarifies the scope of clause 13 (Sanctions Hit Escalation) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

13.4Where circumstances require an exception to clause 13 (Sanctions Hit Escalation), sub-clause 13.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

14.1Nexone shall apply the principles of "Freezing of Assets" in a manner consistent with clause 14. Sub-clause 14.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

14.2For the purposes of clause 14 (Freezing of Assets), the customer acknowledges and agrees that any obligation described in sub-clause 14.2 is a material term of this document and non-compliance may result in restrictions on the account.

14.3Sub-clause 14.3 clarifies the scope of clause 14 (Freezing of Assets) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

14.4Where circumstances require an exception to clause 14 (Freezing of Assets), sub-clause 14.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

15.1Nexone shall apply the principles of "Reporting Obligations" in a manner consistent with clause 15. Sub-clause 15.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

15.2For the purposes of clause 15 (Reporting Obligations), the customer acknowledges and agrees that any obligation described in sub-clause 15.2 is a material term of this document and non-compliance may result in restrictions on the account.

15.3Sub-clause 15.3 clarifies the scope of clause 15 (Reporting Obligations) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

15.4Where circumstances require an exception to clause 15 (Reporting Obligations), sub-clause 15.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

16.1Nexone shall apply the principles of "Cooperation with Authorities" in a manner consistent with clause 16. Sub-clause 16.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

16.2For the purposes of clause 16 (Cooperation with Authorities), the customer acknowledges and agrees that any obligation described in sub-clause 16.2 is a material term of this document and non-compliance may result in restrictions on the account.

16.3Sub-clause 16.3 clarifies the scope of clause 16 (Cooperation with Authorities) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

16.4Where circumstances require an exception to clause 16 (Cooperation with Authorities), sub-clause 16.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

17.1Nexone shall apply the principles of "Handling of False Positives" in a manner consistent with clause 17. Sub-clause 17.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

17.2For the purposes of clause 17 (Handling of False Positives), the customer acknowledges and agrees that any obligation described in sub-clause 17.2 is a material term of this document and non-compliance may result in restrictions on the account.

17.3Sub-clause 17.3 clarifies the scope of clause 17 (Handling of False Positives) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

17.4Where circumstances require an exception to clause 17 (Handling of False Positives), sub-clause 17.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

18.1Nexone shall apply the principles of "Record-Keeping" in a manner consistent with clause 18. Sub-clause 18.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

18.2For the purposes of clause 18 (Record-Keeping), the customer acknowledges and agrees that any obligation described in sub-clause 18.2 is a material term of this document and non-compliance may result in restrictions on the account.

18.3Sub-clause 18.3 clarifies the scope of clause 18 (Record-Keeping) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

18.4Where circumstances require an exception to clause 18 (Record-Keeping), sub-clause 18.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

19.1Nexone shall apply the principles of "Staff Training" in a manner consistent with clause 19. Sub-clause 19.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

19.2For the purposes of clause 19 (Staff Training), the customer acknowledges and agrees that any obligation described in sub-clause 19.2 is a material term of this document and non-compliance may result in restrictions on the account.

19.3Sub-clause 19.3 clarifies the scope of clause 19 (Staff Training) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

19.4Where circumstances require an exception to clause 19 (Staff Training), sub-clause 19.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

20.1Nexone shall apply the principles of "Third-Party Providers" in a manner consistent with clause 20. Sub-clause 20.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

20.2For the purposes of clause 20 (Third-Party Providers), the customer acknowledges and agrees that any obligation described in sub-clause 20.2 is a material term of this document and non-compliance may result in restrictions on the account.

20.3Sub-clause 20.3 clarifies the scope of clause 20 (Third-Party Providers) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

20.4Where circumstances require an exception to clause 20 (Third-Party Providers), sub-clause 20.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

21.1Nexone shall apply the principles of "Delisting Procedures" in a manner consistent with clause 21. Sub-clause 21.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

21.2For the purposes of clause 21 (Delisting Procedures), the customer acknowledges and agrees that any obligation described in sub-clause 21.2 is a material term of this document and non-compliance may result in restrictions on the account.

21.3Sub-clause 21.3 clarifies the scope of clause 21 (Delisting Procedures) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

21.4Where circumstances require an exception to clause 21 (Delisting Procedures), sub-clause 21.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

22.1Nexone shall apply the principles of "Appeals and Reviews" in a manner consistent with clause 22. Sub-clause 22.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

22.2For the purposes of clause 22 (Appeals and Reviews), the customer acknowledges and agrees that any obligation described in sub-clause 22.2 is a material term of this document and non-compliance may result in restrictions on the account.

22.3Sub-clause 22.3 clarifies the scope of clause 22 (Appeals and Reviews) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

22.4Where circumstances require an exception to clause 22 (Appeals and Reviews), sub-clause 22.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

23.1Nexone shall apply the principles of "Governance and Oversight" in a manner consistent with clause 23. Sub-clause 23.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

23.2For the purposes of clause 23 (Governance and Oversight), the customer acknowledges and agrees that any obligation described in sub-clause 23.2 is a material term of this document and non-compliance may result in restrictions on the account.

23.3Sub-clause 23.3 clarifies the scope of clause 23 (Governance and Oversight) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

23.4Where circumstances require an exception to clause 23 (Governance and Oversight), sub-clause 23.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

24.1Nexone shall apply the principles of "Policy Review" in a manner consistent with clause 24. Sub-clause 24.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

24.2For the purposes of clause 24 (Policy Review), the customer acknowledges and agrees that any obligation described in sub-clause 24.2 is a material term of this document and non-compliance may result in restrictions on the account.

24.3Sub-clause 24.3 clarifies the scope of clause 24 (Policy Review) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

24.4Where circumstances require an exception to clause 24 (Policy Review), sub-clause 24.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.