Sanctions Compliance Policy

Purpose

Secure Chain is committed to complying with applicable financial sanctions. This policy explains how we avoid dealings with sanctioned persons and jurisdictions.

Screening

We screen clients and, where relevant, counterparties against applicable UK and international sanctions lists. Engagements involving sanctioned persons, entities or jurisdictions will not be accepted.

Our sanctions controls include:

• Screening at onboarding and, where appropriate, during an engagement
• Declining or discontinuing work that would breach applicable sanctions
• Escalating potential matches to our compliance function for review
• Keeping records of the screening we carry out

Changes to sanctions

Sanctions regimes change frequently. Where a change during an engagement affects our ability to act, we will pause and reassess before continuing.