Sanctions Compliance Policy

1. Purpose

EfficientEther Ltd is committed to complying with applicable sanctions laws and regulations in jurisdictions relevant to our operations, customers, suppliers, and transactions.

2. Scope

This policy applies to all directors, employees, contractors, and representatives of EfficientEther Ltd, and to business activities involving customers, counterparties, suppliers, partners, and payment flows.

3. Applicable Regimes

We operate as a UK-based company and prioritise compliance with UK sanctions laws (including UK sanctions regulations administered by OFSI). We also account for other applicable sanctions regimes where legally relevant, including EU and US controls.

4. Prohibited Activity

• Entering into or continuing business with sanctioned individuals, entities, vessels, or restricted jurisdictions where prohibited.
• Direct or indirect dealings intended to circumvent sanctions restrictions.
• Providing funds, economic resources, goods, or services in breach of applicable sanctions measures.

5. Controls and Due Diligence

• Risk-based screening of customers, counterparties, and key suppliers against relevant sanctions lists.
• Escalation for legal review where potential sanctions hits or higher-risk factors are identified.
• Contractual and onboarding controls to reduce sanctions exposure.
• Ongoing monitoring proportionate to risk profile and transaction type.

6. Reporting and Escalation

Any actual or suspected sanctions issue must be escalated immediately to internal leadership and legal/compliance contacts. Where required by law, we will make appropriate notifications to competent authorities.

7. Training and Accountability

Personnel with customer, supplier, finance, or procurement responsibilities are expected to maintain awareness of sanctions risks and follow relevant procedures. Breaches of this policy may result in disciplinary or contractual action.

8. Review

This policy is reviewed periodically and updated when legal requirements or risk exposure changes. Material updates are published on legal.efficientether.co.uk.

9. Contact

For sanctions compliance questions, contact info@efficientether.co.uk.