9. Sanctions List Screening

Importapay reviews all Customers at the point of registration, and prior to the processing of each transaction by Importapay, against the following sanctions lists:

• OFAC SDN (Specially Designated Nationals)

• UK Treasury List

• UN Consolidated List

• Consolidated Canadian Autonomous Sanctions List

• Nigeria Targeted Financial Sanction List

• FATF Financial Action Task Force List

• OSFI Consolidated List

• World Bank Ineligible Firms List

• Consolidated list of persons, groups, and entities subject to EU financial sanctions

Importapay screens all beneficiaries before sending each transaction. Where a partial match is present for the customer and/or beneficiary, the transaction is held, the customer and beneficiary records are blocked, and the accounts require sign-off by the Compliance Team before proceeding.

If the match is confirmed, it will be flagged and notified to the Chief Compliance Officer. Upon further investigation, the Chief Compliance Officer shall take a decision to make a report if there is sufficient basis for it.