Sanctions policy

As an aiming of global financial institution, V5PAY is committed to combatting financial crime and protecting the integrity of the global financial system. One of the ways in which we meet this objective is through V5 PAY Global Sanctions Policy (the “Policy”).

The Policy is derived from the sanctions resolutions, laws, regulations and regulatory guidance of the United Nations Security Council (“UN”), the United Kingdom (“UK”), the Hong Kong Special Administrative Region (“HK”), the European Union (“EU”) and the United States of America(“US”), the Republic of Philippines, the Republic of Singapore and takes into account broader financial crime concerns. V5PAY is
required to comply with the applicable sanctions’ laws and regulations in all the jurisdictions in which we operate. Further, the Policy seeks, subject to the primacy of local law, to establish a globally consistent standard to effectively manage sanctions compliance risk across all V5PAY wholly or majority-owned or controlled legal entities (“V5 Group Entities and Muon Group Entities”)

Standards

In all jurisdictions in which V5 Group operates. For this reason, we may not be able to support certain business activity even if it is permitted under local laws and regulations.

The Policy defines the minimum standards which all V5PAY Group Entities must comply with, including:

• Prohibiting or restricting customer relationships or transactions/business activity, involving:
  • Parties named on certain sanctions lists issued by the UN, UK, HK, EU or US;
  • Entities and individual list banned of SEC; Violation of AMLC in Philippines.
  • Regulatory breaches or violation on advisory of Banco Central do Brasil, CNBV de México;
  • Parties named on a sanctions list issued by the competent authority in the jurisdiction in which a V5PAY Group Entity operates; and
  • Any entity owned directly or indirectly 50% or more (individually or in the aggregate) or controlled by any of the parties described above, even if the entity is not named on a sanctions list.
• Prohibiting customer relationships, or engaging in transactions or business activity, involving certain countries, territories or Governments1, including:
  • Iran and the Government of Iran;
  • North Korea and the Government of North Korea;
  • Syria and the Government of Syria;
  • The Crimea Region;
  • The Government of Venezuela; and
  • Cuba and the Government of Cuba – relationships and transactions are prohibited to the extent that they involve a US nexus (that is, the US financial system, US persons or US-origin goods).
• Restricting certain transactions and business activity involving, directly or indirectly, certain countries, governments, individuals, entities or industry sectors, including:
  • Belarus – prohibiting the direct funding of the Government of Belarus;
  • Libya – freezing of assets of certain Libyan entities (and any subsidiaries owned 50% or more or controlled by these entities) held outside Libya;
  • Russia – engaging in transactions or business activity involving:
    • the Russian military, intelligence or defense or related materiel sector;
    • the primary market for bonds issued by, or lending funds to, the Russian Sovereign outside of Russia;
    • the provision of goods, technology and services in support of certain Russian energy projects; or
    • debt and equity of certain entities operating in the Russian financial, energy and defense sectors; and
  • Zimbabwe – prohibiting the direct funding of the Government of Zimbabwe.

V5 Pay may, in its sole discretion, agree to process certain transactions prohibited or restricted under the Policy that are authorized by a license from an appropriate authority or are otherwise permitted under applicable laws and regulation, such as those which relate to humanitarian aid. These transactions will be considered on a case-by-case basis and must be submitted in advance to V5 for consideration and approval.

V5 Pay may, in its sole discretion, also decide not to process transactions, provide transaction services or otherwise engage in transactions or other activity even where permitted by applicable sanctions laws and regulations where these activities fall outside of V5 Pay risk appetite.

In complying with applicable sanctions laws or regulations or the Policy, the processing of customer transactions may be delayed while we conduct additional due diligence on the underlying transaction and/or the parties involved. V5 Pay will block/freeze or reject transactions that appear to violate sanctions laws or regulations or the Policy where required to do so under applicable sanctions laws or regulations or the Policy, or will return transactions where they fall outside V5 Pay’s risk appetite. Further, V5 Pay will comply with obligations to report sanctions violations to the relevant regulatory authority, including where a violation relates to any attempt by a customer to evade or circumvent sanctions laws and regulations.