1. Statement
Unlshd Ltd, trading as NeptunePay ("Unlshd"), is committed to complying with all applicable economic and trade sanctions, including those imposed by the United Nations Security Council, the European Union, the Republic of Cyprus, the United Kingdom (including HM Treasury Office of Financial Sanctions Implementation), and the United States Office of Foreign Assets Control ("OFAC"), and with any other sanctions regime applicable to Unlshd, its directors, employees, partner acquirers, or merchants.
Although Unlshd does not handle, hold, or transmit funds, and is not itself a designated "obligated entity" for sanctions purposes in every jurisdiction in which it operates, Unlshd applies a comprehensive sanctions-compliance framework as a matter of corporate policy and as a condition of its commercial relationships with regulated partner acquirers.
2. Scope
This Statement applies to all directors, officers, employees, contractors, and agents of Unlshd, and to all merchants and prospective merchants. It applies globally and without exception.
3. Prohibited Activity
Unlshd will not, directly or indirectly:
• onboard, support, introduce to an acquirer, or knowingly continue to support any merchant that is the subject of sanctions imposed by any applicable sanctions regime;
• onboard or support any merchant whose ultimate beneficial owners, directors, or senior managers are sanctioned persons;
• onboard or support any merchant established in, or operating substantially from, a comprehensively sanctioned jurisdiction (currently including, without limitation, Cuba, Iran, North Korea, Syria, the so-called Donetsk and Luhansk People's Republics, Crimea, and any other jurisdiction subject to comprehensive sanctions from time to time);
• participate in, facilitate, or knowingly tolerate any transaction that is intended to evade sanctions;
• act in any way that would expose Unlshd, its partner acquirers, or any sponsor bank to secondary sanctions risk under United States or other extraterritorial regimes.
4. Screening
Unlshd screens, against consolidated sanctions lists from a recognised commercial provider, the following at onboarding and on an ongoing basis:
• the merchant entity;
• every ultimate beneficial owner of the merchant;
• every director and senior manager of the merchant;
• any other natural or legal person identified as relevant during due diligence.
Screening covers, at minimum: UN consolidated list, EU consolidated list, UK HMT consolidated list, OFAC SDN and Sectoral Sanctions Identifications lists, and any other list designated by the partner acquirer or by Unlshd's Compliance Function.
Screening is repeated on a continuous or regular basis throughout the merchant relationship, and is repeated immediately on any update to the underlying sanctions lists.
5. Hits and Escalation
Any potential sanctions match ("hit") is escalated immediately to the MLRO/Compliance Officer for evaluation. Pending evaluation:
• no further onboarding step is taken in respect of the merchant;
• no funds are introduced or routed in respect of the merchant;
• the partner acquirer is informed where contractually required.
The MLRO/Compliance Officer evaluates the hit, taking external legal advice where necessary, and determines whether: (i) the hit is a true match (in which case the relationship is declined, suspended, or terminated and any reporting obligation is fulfilled); (ii) the hit is a false positive (in which case it is dismissed with a documented rationale); or (iii) further information is required.
6. Geographic Restrictions
Beyond the comprehensively sanctioned jurisdictions listed above, Unlshd applies elevated restrictions to merchants established in or operating from jurisdictions identified as higher-risk by the FATF, the EU list of non-cooperative jurisdictions for tax purposes, or by partner acquirers. The current list is maintained by the Compliance Function. Acceptance of merchants in such jurisdictions is conditional on enhanced due diligence and senior-management approval.
7. No Circumvention
Unlshd will not assist, advise, or accommodate any merchant or any other party in any structure, arrangement, or transaction that has, as one of its purposes, the evasion or circumvention of sanctions. This includes, without limitation, intermediated routing, false MCC declaration, false beneficial-ownership declaration, transit through non-sanctioned jurisdictions to obscure end-user locations, and "front-company" arrangements.
8. Training and Awareness
All staff receive sanctions training on induction and at least annually thereafter. Training covers identification of sanctioned persons and jurisdictions, recognition of evasion typologies, escalation procedures, and the consequences of breach.
9. Reporting Breaches
Any actual or suspected breach of sanctions, or any indicator of attempted sanctions evasion by a merchant, must be reported immediately to the MLRO/Compliance Officer at compliance@neptunepay.io. Where Unlshd determines that a sanctions breach has occurred, it will take prompt remedial action, including notification of the partner acquirer and, where required, of the relevant competent authority.
10. Governance
This Statement is owned by the Compliance Function and approved by the Board of Directors of Unlshd Ltd. It is reviewed at least annually and on the occurrence of any material change in the applicable sanctions environment, in Unlshd's business, or in partner-acquirer requirements.
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