Counter-Terrorist Financing Policy

Purpose

Secure Chain has zero tolerance for the financing of terrorism. This policy sets out how we work to ensure our services are never used to facilitate it.

Our approach

Counter-terrorist financing (CTF) controls operate alongside our AML and sanctions measures. We screen engagements for connections to terrorist financing and treat any such indicator as grounds to pause and escalate.

Our controls include:

• Client identity verification and risk assessment
• Screening against relevant sanctions and watch lists
• Escalation of any suspected terrorist-financing indicator to our compliance function
• Reporting to the appropriate authorities where legally required

Legal reporting

Where the law requires us to report a suspicion of terrorist financing, we will do so, and may be legally prohibited from disclosing that report to the client.