Sanctions Compliance Policy

1. Purpose

This policy establishes Double J Global Pte. Ltd.'s ("the Company") internal framework for identifying and mitigating risks associated with economic and trade sanctions. The Company is committed to ensuring that it does not engage in transactions with individuals, entities, or countries subject to international sanctions, directly or indirectly.

2. Legal and Regulatory Framework

The Company complies with international sanctions regimes, including but not limited to:

• - United Nations (UN) Security Council Resolutions
• - United States Office of Foreign Assets Control (OFAC) Sanctions Programs
• - European Union (EU) Sanctions Regulations
• - Monetary Authority of Singapore (MAS) Notices on Targeted Financial Sanctions
• - Other country-specific regulations applicable to our operations or financial partners

The Company voluntarily adopts these frameworks despite not being a licensed financial institution under the Singapore Payment Services Act (PSA).

3. Scope

This policy applies to:

• All clients (businesses and individuals) onboarded via the Merchant of Record (MoR) service provider
• All payments, transactions, B2B remittance to partners, and settlements
• All counterparties, employees, and third-party vendors associated with the Company
• All geographies in which the Company provides or facilitates services

4. Screening Procedures

The Company conducts sanctions screening through automated and manual controls. Screening applies at:

5. Positive Match and Escalation

If a potential match is identified:

• The transaction is immediately held or blocked
• The case is escalated to the Compliance Officer
• Further information is gathered for verification
• If confirmed, the Company will freeze any relevant access and report the matter to appropriate authorities or partners

6. High-Risk Jurisdictions and Restrictions

Double J Global restricts or prohibits any business or transaction that:

• Involves comprehensively sanctioned countries (e.g., North Korea, Iran, Syria)
• Originates from or is routed through FATF-designated high-risk jurisdictions
• Violates Stripe, Visa, Mastercard, or banking partner policies
• Attempts to circumvent restrictions via proxy/VPN/IP manipulation

Geofencing and card-issuing bank restrictions are used to enforce these rules.

7. Recordkeeping

All sanctions screening logs, case reviews, and compliance reports are securely retained for a minimum of five (5) years and are accessible to internal audit, payment processors, or government agencies upon request.

8. Training and Governance

• All employees undergo annual training on sanctions risks and screening processes
• A designated Compliance Officer is responsible for reviewing sanctions enforcement and updating procedures based on regulatory changes
• Internal audits may be performed to test the effectiveness of this policy

9. Review and Amendments

This policy is reviewed annually or when there is a significant change in applicable laws, the Company's geographic scope, or risk exposure.