Sanctions Policy

This Sanctions Policy (the “Policy”) is issued by Kohle Capital Markets Limited (the “Company”, “we”, “us”, or “our”) and sets out the framework by which the Company identifies, assesses, and manages sanctions risk in connection with digital services operated under the KCM Trade brand (the “Services”).

This Policy forms part of the Company’s broader financial crime compliance framework alongside the AML and KYC Policy.

The Company holds an Investment Dealer (Full Service Dealer) licence (Licence No. C117022600, SEC-2.1B) issued by the Financial Services Commission of Mauritius (FSC Mauritius) and is subject to sanctions compliance obligations under the laws of the Republic of Mauritius and applicable international sanctions regimes.

1. Purpose

The purpose of this Policy is to:

• Ensure that the Company does not directly or indirectly provide financial services to persons, entities, vessels, or jurisdictions that are subject to applicable sanctions
• Establish a framework for screening clients, transactions, and counterparties against relevant sanctions lists
• Ensure the Company’s compliance with mandatory sanctions obligations under Mauritian law and applicable international sanctions regimes
• Protect the Company, its employees, directors, and stakeholders from sanctions-related legal, regulatory, and reputational risk

2. Sanctions Regimes

The Company applies compliance measures in respect of the following sanctions regimes:

The Company may add additional sanctions regimes to its monitoring programme from time to time in response to regulatory guidance, correspondent banking requirements, or changes in the Company’s business activities.

3. Prohibited Relationships and Transactions

The Company will not:

• Open an account for, or provide Services to, any individual or entity that appears on any applicable sanctions list, is owned or controlled by such a person or entity, or is acting on behalf of such a person or entity
• Process any transaction that involves, directly or indirectly, a sanctioned person, entity, vessel, or jurisdiction
• Provide Services to any person resident in or incorporated in a jurisdiction subject to comprehensive or targeted sanctions measures and/or FATF counter-measures, including but not limited to:
  • North Korea (Democratic People’s Republic of Korea) — subject to UNSC comprehensive sanctions
  • Iran — subject to UNSC and multilateral sanctions
  • Myanmar — subject to FATF Call for Action (blacklist); subject to targeted sanctions under EU, UK, and US regimes
  • Syria — subject to UNSC and multilateral sanctions
  • Sudan — subject to applicable sanctions measures
• Facilitate any transaction that would cause the Company or any third party to violate applicable sanctions laws

The above list of prohibited jurisdictions is not exhaustive. Sanctions designations and country-level measures are subject to change, and the Company’s prohibited list is updated on a continuous basis in response to changes in applicable sanctions regimes.

4. Sanctions Screening Procedures

4.1 Client Screening at Onboarding

All prospective clients are screened against applicable sanctions lists as part of the account opening and identity verification process. Screening is conducted using the Company’s third-party identity verification and compliance service provider, ShuftiPro, which performs automated sanctions and PEP screening at the time of KYC submission.

No account will be opened for a prospective client whose identity screening results in a positive match against any applicable sanctions list pending further review and, if necessary, escalation to the Company’s compliance function.

4.2 Ongoing Screening

The Company conducts periodic re-screening of its existing client base against applicable sanctions lists. In addition, the Company may conduct event-driven re-screening of clients where there is reason to believe that a client’s sanctions status may have changed, including in response to:

• New designations or amendments to applicable sanctions lists
• Changes in client information or behaviour
• Alerts or notifications from screening systems or third-party providers

4.3 Transaction Screening

Certain transactions — including deposits, withdrawals, and wire transfers — may be screened against applicable sanctions lists and checked for red flags indicating potential sanctions evasion.

4.4 Screening Thresholds and False Positives

Automated screening may generate potential matches (alerts) that require manual review to determine whether they represent a true sanctions match or a false positive. All alerts are reviewed by the Company’s compliance function. Accounts or transactions subject to a credible sanctions alert will be placed on hold pending resolution of the alert.

5. Frozen Assets and Account Restrictions

Where the Company identifies or is directed by a competent authority that a client, transaction, or asset is subject to a financial prohibition under applicable sanctions law:

• The Company will immediately freeze the relevant account or assets without notice
• The Company will not conduct any further transactions on or with the frozen account or assets, except as expressly required or permitted by applicable law or a competent authority direction
• The Company will report the matter to the appropriate authority in accordance with applicable law, including the Financial Intelligence Unit of Mauritius and, where required, the FSC Mauritius
• The Company will not disclose to the subject of a freeze that their account or assets have been frozen, where doing so would constitute a “tipping off” offence under applicable law

6. Sanctions Evasion

The Company is alert to indicators of potential sanctions evasion, including but not limited to:

• Use of corporate structures, nominee arrangements, or third parties to obscure the involvement of a sanctioned person or jurisdiction
• Use of multiple accounts or jurisdictions to fragment otherwise prohibited transactions
• Unusual payment routing through high-risk or sanctions-adjacent jurisdictions
• Inconsistencies in client-provided information relating to source of funds, nationality, or beneficial ownership
• Connections between client funds or counterparties and known sanctions evasion networks

Where sanctions evasion is suspected, the Company will escalate the matter to its compliance function and, where required, file a suspicious transaction report with the Financial Intelligence Unit of Mauritius.

7. Training and Awareness

The Company’s employees, officers, and directors who are involved in client onboarding, account management, transaction processing, or compliance functions receive training on sanctions compliance obligations, screening procedures, and escalation protocols as part of the Company’s ongoing compliance training programme.

8. No Advisory Service on Sanctions

This Policy does not constitute legal advice on sanctions compliance. The sanctions compliance landscape is complex and subject to rapid change. Persons who are uncertain as to whether a proposed transaction or business relationship would violate applicable sanctions laws should seek independent legal advice.

9. Reporting and Regulatory Co-operation

The Company co-operates fully with:

• The Financial Intelligence Unit of Mauritius (FIU) in connection with suspicious transaction reports and financial prohibition orders
• The Financial Services Commission of Mauritius (FSC) in connection with licensing conditions and regulatory requests relating to sanctions
• Other competent authorities, law enforcement, and regulatory bodies as required by applicable law

10. Review and Amendment

This Policy is reviewed at least annually, or following any material change in applicable sanctions laws, regulations, or regulatory guidance. The Company’s sanctions screening programme is reviewed on an ongoing basis to ensure that the screening tools and lists in use remain current and effective.

11. Contact Information

For enquiries relating to this Policy or sanctions-related compliance matters, please contact:

Kohle Capital Markets Limited
Email: CS@kcmtrade.com
Website: https://www.kcmtrade.com