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SANCTIONS POLICY ToGoTransfer

Effective Date: December 1, 2025
To Go Transfer FZ LLC
P.O.Box 4422, Twin Towers, Fujairah Creative City – Media Free Zone, UAE
Email: info@togotransfer.com

1. POLICY STATEMENT

To Go Transfer FZ LLC (“Company”) conducts its business in strict compliance with international and national sanctions requirements, including UAE laws and directives, Central Bank of the UAE (CBUAE) regulations, UN, EU, US (OFAC), UK (OFSI) sanctions, and other applicable jurisdictions.
The Company has implemented procedures for sanctions screening, ongoing monitoring, risk assessment, and regular staff training.
The Company maintains a zero-tolerance policy for sanctions violations. Non-compliance may result in disciplinary, administrative, or criminal liability.

2. SCOPE

This Policy applies to all Company employees, directors, agents, temporary and contract workers, contractors, partners, and any third parties acting on behalf of the Company in all jurisdictions.

3. SANCTIONS: DEFINITION AND SOURCES

Sanctions are legally binding restrictions or prohibitions imposed by international bodies or governments against certain countries, regions, individuals, or organizations.
The Company complies with sanctions lists, including:

  • UN Sanctions Lists (UN Security Council)
  • US OFAC SDN and Non-SDN Lists
  • EU Consolidated Sanctions List
  • UK HMT/OFSI Sanctions Lists
  • UAE-specific lists:
    • National Terrorist List (Cabinet Resolution No. 74/2021 and updates)
    • Local Terrorist List (Ministry of Justice, CBUAE Guidance)
    • UAE Sanctions List (official government publications)
    • CBUAE AML/CFT Guidelines

4. INTERNAL COMPLIANCE PROCEDURES

4.1. All clients, carriers, contractors, partners, and payment agents are screened against global and local sanctions lists.

4.2. Screening is performed:

  • during onboarding (registration, start of cooperation);
  • through ongoing monitoring (real-time and batch screening whenever lists are updated).

4.3. If a match or doubt is identified (including indirect links — e.g., nominees, proxy companies, affiliated structures), the Company will:

  • suspend the transaction or service;
  • notify the regulator;
  • file a report via the goAML system (CBUAE) when required.

4.4. Prohibited activities include:

  • providing services or processing payments for sanctioned persons or entities;
  • cooperating with companies whose ultimate beneficial owners (UBOs) are sanctioned persons;
  • facilitating the circumvention or concealment of sanctions in any way.

5. UAE-SPECIFIC REQUIREMENTS (CBUAE)

  • Mandatory checks against the official UAE Sanctions Register.
  • Use of the goAML system for reporting suspicious or sanctions-related activities.
  • Retention of screening records, analysis results, correspondence, and responses for at least 5 years (or up to 7 years where AML/KYC laws apply).

6. ENHANCED DUE DILIGENCE (EDD)

For high-risk clients or transactions (including high-risk countries or PEP-related cases), the Company applies Enhanced Due Diligence (EDD), which may include:

  • additional information and documentation;
  • proof of source of funds;
  • analysis of UBO structure.

7. RISK ASSESSMENT AND TRAINING

  • Regular reassessment of geographic, business, and transactional risks related to sanctions.
  • Ongoing staff training on AML/CTF and sanctions compliance (CBUAE training, internal workshops, newsletters).
  • Mandatory onboarding training for new employees on sanctions compliance and reporting procedures.

8. RESPONSIBLE OFFICER

The Compliance Officer (or Company Director) is responsible for implementation and enforcement of this Sanctions Policy.
Contact for urgent communication: info@togotransfer.com

9. POLICY REVIEW

This Policy is reviewed at least annually or whenever significant changes occur in sanctions regulations or lists. Updated versions are communicated to employees and key partners.

10. APPENDICES

Appendix 1. Information and Documents for Sanctions Screening

For Legal Entities:

  • name, address, registration details, country;
  • business activities and regions;
  • ownership structure (UBO);
  • documents confirming identity/authority.

For Individuals:

  • full name, address, nationality;
  • passport/ID;
  • countries of presence;
  • additional EDD information if required.

Appendix 2. Restricted Territories

The Company does not provide services to persons or entities located in or connected with the following territories (list updated based on CBUAE, EU, OFAC, and other authorities):

Afghanistan, Myanmar, Burundi, Central African Republic, Côte d’Ivoire, Crimea (Ukraine), North Korea, DRC, Haiti, Iran, Libya, Mali, Nicaragua, Donetsk/Luhansk/Kherson/Zaporizhzhia regions of Ukraine, Cuba, Guinea, Iraq, Russia, Somalia, Syria, South Sudan, Yemen, Zimbabwe, among others.

11. REPORTING AND VIOLATIONS

Any employee who identifies a potential sanctions breach must immediately report it to the Compliance Officer.

Violations may result in:

  • disciplinary action (up to termination);
  • termination of contracts with contractors/partners;
  • administrative fines, criminal prosecution, and regulatory sanctions.