Version: 1.0
Effective Date: 01/01/2024
Last Updated: 07/07/2026
1. Purpose
Octalas Pay is committed to conducting business with the highest standards of integrity and regulatory compliance. This Sanctions Compliance Policy establishes the framework through which Octalas Pay identifies, assesses, and manages sanctions risks to prevent its products and services from being used to facilitate unlawful or prohibited financial activity.
The purpose of this Policy is to ensure compliance with applicable international sanctions laws and regulations while protecting the integrity of the global financial system.
2. Scope
This Policy applies to:
- All Octalas Pay employees
- Directors and officers
- Contractors and consultants
- Business partners
- Merchants
- Enterprise clients
- API customers
- Payment services provided through Octalas Pay
3. Our Commitment
Octalas Pay is committed to:
- Preventing sanctioned individuals and organisations from accessing our services.
- Maintaining effective sanctions screening procedures.
- Monitoring customer relationships throughout their lifecycle.
- Cooperating with regulatory and law enforcement authorities.
- Maintaining a risk-based sanctions compliance programme.
4. Sanctions Framework
Where applicable, Octalas Pay screens customers and transactions against sanctions issued by recognised authorities, including:
- United Nations Security Council (UN)
- European Union (EU)
- UK Office of Financial Sanctions Implementation (OFSI)
- U.S. Office of Foreign Assets Control (OFAC)
- Other applicable national or regional sanctions authorities relevant to our operations
The sanctions lists monitored may change as regulatory requirements evolve.
5. Customer Screening
Customers may be screened:
- During onboarding
- Prior to account approval
- Before processing transactions
- Periodically throughout the business relationship
- Whenever customer information changes
- When regulatory updates require rescreening
Screening may include:
- Individual names
- Company names
- Ultimate Beneficial Owners (UBOs)
- Directors
- Shareholders
- Politically Exposed Persons (PEPs)
- Associated entities
6. Transaction Screening
Transactions may be monitored to identify:
- Sanctioned counterparties
- Restricted countries or territories
- High-risk payment routes
- Suspicious transaction patterns
- Attempts to evade sanctions controls
Transactions may be delayed, declined, suspended, or investigated where necessary.
7. Geographic Risk
Octalas Pay may restrict or prohibit services involving jurisdictions that present elevated sanctions or regulatory risks.
Risk assessments may consider:
- International sanctions
- Government restrictions
- Regulatory guidance
- Financial crime risks
- Internal risk assessments
Supported jurisdictions may change without notice where required by law or regulation.
8. Enhanced Due Diligence
Enhanced Due Diligence (EDD) may be applied where sanctions-related risks are identified, including:
- Complex ownership structures
- Cross-border payment activity
- High-risk industries
- Elevated geopolitical risk
- Politically Exposed Persons
- Unusual transaction behaviour
Additional documentation or verification may be required before services are provided.
9. Ongoing Monitoring
Sanctions compliance is not limited to onboarding.
Octalas Pay conducts ongoing monitoring designed to identify:
- Changes to sanctions lists
- Changes in customer ownership
- Changes in business activity
- Emerging geopolitical risks
- Transaction anomalies
Customer risk profiles may be updated throughout the relationship.
10. Suspicious Activity
Where sanctions concerns arise, Octalas Pay may:
- Request additional documentation.
- Delay processing.
- Suspend accounts.
- Freeze transactions where legally required.
- Restrict access to services.
- Terminate customer relationships.
- Report matters to competent authorities where required by law.
Where prohibited by law, customers may not be informed that such reports have been made.
11. Third-Party Screening
Octalas Pay may utilise trusted third-party providers to assist with:
- Sanctions screening
- Identity verification
- Beneficial ownership verification
- Adverse media monitoring
- Ongoing compliance monitoring
12. Record Keeping
Records relating to sanctions screening, customer verification, compliance decisions, and investigations will be retained for the periods required by applicable law and regulatory obligations.
13. Employee Responsibilities
Employees involved in customer onboarding, operations, compliance, risk management, and payment processing receive appropriate training to:
- Identify sanctions risks
- Escalate potential concerns
- Follow internal compliance procedures
- Support regulatory obligations
Employees are required to report suspected sanctions breaches immediately through internal reporting procedures.
14. Governance
Responsibility for sanctions compliance rests with the Compliance function, supported by senior management.
The Policy will be reviewed periodically to ensure it remains effective and reflects changes in applicable laws, regulations, industry standards, and business operations.
15. Regulatory Cooperation
Octalas Pay will cooperate with competent regulatory authorities, financial intelligence units, banking partners, payment providers, and law enforcement agencies where disclosure is required under applicable law or regulation.
16. Disclaimer
Octalas Pay reserves the right to refuse, suspend, or terminate services where sanctions risks cannot be adequately managed or where continued service would expose the company, its partners, or customers to unacceptable legal, regulatory, or financial risk.
17. Contact
Compliance Department
Octalas Pay
Email: compliance@octalaspay.com
Website: www.octalaspay.com
