Sanctions Policy

1. Purpose

Bankario is committed to complying with applicable economic and trade sanctions laws and regulations. This Sanctions Policy outlines our approach to preventing the use of our Services by sanctioned individuals, entities, and jurisdictions.

Our goal is to maintain a secure platform while supporting lawful financial activity.

2. Scope

This Policy applies to:

• All Bankario customers;
• Authorized users;
• Businesses and organizations;
• Beneficial owners;
• Directors and authorized representatives;
• Third parties interacting with the Services where applicable.

3. Compliance Program

As part of our compliance framework, Bankario maintains risk-based controls designed to identify and prevent prohibited activity.

These controls may include:

• Identity verification (KYC/KYB);
• Sanctions screening;
• Ongoing customer monitoring;
• Transaction monitoring;
• Risk assessments;
• Enhanced due diligence where appropriate.

Customers may be re-screened periodically throughout their relationship with Bankario.

4. Restricted Persons

Bankario does not knowingly provide Services to persons or organizations that are subject to applicable sanctions.

This includes individuals or entities that are:

• Listed on applicable sanctions lists maintained by competent authorities;
• Owned or controlled, directly or indirectly, by sanctioned persons;
• Acting on behalf of sanctioned persons or entities.

5. Restricted Jurisdictions

Bankario may restrict or prohibit access to the Services in jurisdictions that are subject to comprehensive sanctions or where required by applicable law or our infrastructure partners.

Availability of the Services may change as sanctions regulations evolve.

6. Transaction Monitoring

Transactions may be reviewed to identify potentially prohibited activity, including:

• Payments involving sanctioned persons or entities;
• Transactions connected to restricted jurisdictions;
• Attempts to evade sanctions controls;
• Suspicious transaction patterns;
• Activity inconsistent with the customer's expected profile.

Where appropriate, transactions may be delayed, rejected, returned, or reported in accordance with applicable legal and regulatory requirements.

7. Customer Responsibilities

Customers must not use Bankario to:

• Conduct transactions prohibited by applicable sanctions laws;
• Facilitate transactions for sanctioned persons or entities;
• Circumvent sanctions or export control regulations;
• Provide false or misleading information regarding transaction counterparties or beneficial ownership.

Customers are responsible for ensuring that their use of the Services complies with applicable laws.

8. Requests for Information

Bankario may request additional information or documentation to assess sanctions-related risks.

Examples include:

• Source of funds;
• Purpose of a transaction;
• Identity of counterparties;
• Supporting business documentation;
• Beneficial ownership information.

Failure to provide requested information may result in delayed, restricted, or suspended Services.

9. Enforcement

Where required by law, regulation, or contractual obligations, Bankario may:

• Decline or reject transactions;
• Suspend or restrict account functionality;
• Freeze or block access to certain Services where legally required;
• Terminate customer relationships;
• Report activity to competent authorities where applicable.

Bankario is not liable for delays or restrictions resulting from compliance with applicable sanctions obligations.

10. Third-Party Providers

Certain banking, payment, card, custody, compliance, and financial infrastructure services available through Bankario are provided by independent third-party partners.

Those partners maintain their own sanctions compliance programs and may independently decline, delay, restrict, or reject transactions in accordance with their legal or regulatory obligations.

11. Changes to this Policy

Bankario may update this Sanctions Policy at any time to reflect changes in applicable laws, regulations, or internal compliance procedures.

The latest version will always be available through our website or within the Services.