Sanctions Compliance Policy

Policy Overview

POPS.GG (operated by CASH.BH LTD) maintains a sanctions compliance program, proportionate to a small company, to ensure adherence to all applicable international sanctions regimes. This policy outlines our procedures for screening, monitoring, and reporting in compliance with UK, EU, UN, and US sanctions requirements.

We are committed to preventing any transactions or business relationships with sanctioned individuals, entities, or jurisdictions, and maintaining robust controls to detect and prevent sanctions violations.

Monitored Sanctions Lists

1. OFAC Sanctions Lists (United States)

Specially Designated Nationals and Blocked Persons List (SDN)
Consolidated Sanctions List
Sectoral Sanctions Identifications List (SSI)
Foreign Sanctions Evaders List (FSE)
Non-SDN Palestinian Legislative Council List

2. UK Sanctions Lists

UK Sanctions List (Office of Financial Sanctions Implementation)
UK Consolidated List of Financial Sanctions Targets
Asset Freeze Targets

3. EU Sanctions Lists

EU Consolidated List of Sanctions
EU Financial Sanctions Files
Country-specific EU sanctions regimes

4. UN Sanctions Lists

UN Security Council Consolidated List
UN 1267/1989 ISIL (Da'esh) and Al-Qaida Sanctions List
UN Taliban Sanctions List

Screening Procedures

Customer Onboarding Screening

Initial Screening: New publishers and advertisers are checked manually against the UK, EU, UN and US consolidated lists before onboarding and on material change; screening uses the publicly available official lists
Beneficial Owner Screening: Known beneficial owners (25%+ ownership) and directors are included in the manual check where identified
Geographic Screening: Verification that business operations are not in sanctioned jurisdictions

Ongoing Monitoring

Re-screening: Existing publishers and advertisers are re-checked manually on material change (ownership, location, business activity) using the current official lists

Enhanced Screening for High-Risk

Enhanced due diligence for customers with connections to high-risk countries
Additional manual checks of related parties where identified
Periodic re-checks for elevated risk customers

Screening Method & Sources

Manual Screening: New publishers and advertisers are checked manually against the UK, EU, UN and US consolidated lists before onboarding and on material change; screening uses the publicly available official lists. Checks include:

Name variations (aliases, transliterations, abbreviations)
Date of birth and address comparison where available
A record of each check and its outcome

Data Sources:

The publicly available official consolidated lists published by the UK (OFSI), EU, UN and US (OFAC)

Match Resolution Procedures

1. Potential Match Identification

A potential match is identified during the manual check
Account activity is paused pending manual review

2. Investigation Process

Comparison of all available identifying information (name, DOB, address, nationality)
Review of additional information provided by customer during onboarding
Consultation of external databases and public records
Documentation of decision rationale with supporting evidence

3. False Positive Resolution

Clear documentation of why match is determined to be false positive
Record retained in our compliance records
Account restrictions lifted following the director’s approval

4. True Positive Actions

Account terminated; no further business is conducted
Cessation of all business activities
Reporting to relevant authorities within required timeframes
Full cooperation with law enforcement and regulators

Reporting Obligations

UK Reporting (OFSI)

We do not transact with designated persons; any UK reporting obligation is made to OFSI
Breach or attempted breach notifications made promptly

US Reporting (OFAC)

We do not transact with designated persons; any UK reporting obligation is made to OFSI
Voluntary self-disclosure of potential violations where required

Internal Reporting

Reviewed annually by the company director
Any confirmed match is recorded and acted on by the company director

Training & Governance

Staff Training

The director keeps up to date with sanctions developments
Contractors handling onboarding are briefed on these procedures

Governance Structure

Company Director: Responsible for program oversight and regulatory reporting
Review: Reviewed annually by the company director

Record Retention

All screening records retained for minimum 5 years (UK) / 5 years (US)
Match investigation documentation permanently retained
Briefing records maintained throughout engagement + 5 years
Policy and procedure versions archived with change history

Prohibited Activities

POPS.GG strictly prohibits:

Any transactions with designated persons or entities on sanctions lists
Business relationships with customers in comprehensively sanctioned countries
Processing payments to or from sanctioned jurisdictions
Facilitating transactions that directly or indirectly benefit sanctioned parties
Engaging in sanctions evasion or circumvention activities
Providing services that could be used to evade sanctions

Contact Information

For questions regarding our Sanctions Compliance Policy:

Company Director (sanctions compliance)

CASH.BH LTD

71–75 Shelton Street, Covent Garden

London, WC2H 9JQ, United Kingdom

Email: compliance@pops.gg