1. Policy Summary
Name: Financial Sanctions and Counter Terrorist Financing (FS/CTF)
Key Terms: Anti-Terrorist Finance / Finance Risk
2. Purpose and Scope
Subculture (“the Company”) is built on a foundation of trust, integrity, and ethical conduct. To uphold these values and meet the expectations of our clients, stakeholders, and regulatory authorities, Subculture maintains a zero-tolerance stance toward any transaction or relationship that may contribute to terrorist financing or benefit sanctioned individuals or entities.
This policy outlines Subculture’s minimum requirements for financial sanctions (FS) and counter terrorist financing (CTF). It applies to all Subculture entities, employees, and business units, regardless of geographic location.
3. Policy Statement
- Zero Tolerance
Subculture has no appetite for any business relationship or transaction that directly or indirectly:- Contributes to the financing of terrorism, or
- Provides a benefit (financial or otherwise) to sanctioned individuals or organizations.
- Compliance with Laws and Regulations
This policy is designed to ensure Subculture complies with all relevant statutory and regulatory obligations concerning financial sanctions and the prevention of terrorist financing. - Global Applicability
- All Subculture employees, contractors, and subsidiaries must adhere to this policy.
- Where local requirements exceed these minimum standards, local entities must implement more stringent controls.
4. Regulatory Framework
Subculture is cognizant of and complies with sanctions and counter terrorist financing laws and regulations issued by, at a minimum, the following authorities:
- United Nations Security Council (UNSC)
- United States Office of Foreign Assets Control (OFAC)
- Her Majesty’s Treasury Office for Financial Sanctions Implementation (OFSI)
In addition, Subculture adheres to any other applicable national or regional regulations in the jurisdictions where we operate.
5. Roles and Responsibilities
- Policy Owner: Head of Compliance (or designated equivalent)
Responsible for maintaining and updating this policy to reflect evolving regulatory requirements. - All Employees:
Each employee is responsible for understanding and adhering to this policy, as well as participating in any required training. Employees must promptly escalate any concerns or suspicious activities related to financial sanctions or terrorist financing. - Local Compliance Teams:
Ensure that local procedures and controls meet or exceed the standards outlined in this policy, especially in jurisdictions with stricter legislation.
6. Policy Governance
- Approval and Oversight:
Approved by the Compliance and Risk Oversight Committee (or equivalent body).- Approval Date: 01 January 2026
- Next Review Date: 01 January 2027
- Monitoring and Reporting:
Regular monitoring is performed to ensure ongoing compliance with sanctions regulations and CTF obligations. Any breaches or compliance concerns are reported to the Compliance and Risk Oversight Committee.
7. Key Controls and Processes
- Screening and Due Diligence
- Conduct screening of clients, partners, and transactions against relevant sanctions lists to identify potential restricted parties or high-risk activities.
- Maintain robust Know Your Customer (KYC) and customer due diligence (CDD) processes.
- Transaction Monitoring
- Employ risk-based monitoring systems to detect unusual or potentially suspicious transactions related to money laundering, terrorist financing, or sanctioned parties.
- Employ risk-based monitoring systems to detect unusual or potentially suspicious transactions related to money laundering, terrorist financing, or sanctioned parties.
- Training and Awareness
- Provide regular training to employees on sanctions regulations, terrorist financing risks, and proper escalation procedures.
- Provide regular training to employees on sanctions regulations, terrorist financing risks, and proper escalation procedures.
- Record Keeping
- Retain all pertinent records, screening results, and supporting documentation in line with legal retention requirements.
- Retain all pertinent records, screening results, and supporting documentation in line with legal retention requirements.
- Reporting Obligations
- Promptly escalate and report any breaches, suspicious activities, or sanctions hits to the relevant authorities in accordance with local regulations.
8. Consequences of Non-Compliance
Failure to comply with this policy or with applicable sanctions and CTF regulations can result in legal and regulatory consequences for both Subculture and individual employees. Disciplinary actions, up to and including termination of employment, may be taken if breaches of this policy occur.
9. Review and Amendments
This policy is subject to review at least every two years—or earlier if necessary to reflect significant changes in applicable laws or Subculture’s business environment. Amendments must be approved by the Compliance and Risk Oversight Committee.