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SAMPLE - DRAFT FOR COUNSEL REVIEW. Not yet executed by Global Hands, Inc. (Operator) or JIL Sovereign Technologies, Inc. (Licensor); not binding on any party.
Operational

Sanctions Compliance Policy

Multi-list screening (OFAC, EU, UK HMT, UN, AU DFAT, CA OSFI, jurisdictional).

Effective: 2026-05-04Last updated: 2026-05-04Version 1.0 (sample)

1. Multi-List Screening

The Platform screens organizations, executives, authorized signers, and beneficial owners against the following lists at application submission, milestone approval, and on a daily refresh basis:

  • OFAC Specially Designated Nationals (SDN), Non-SDN Palestinian Legislative Council, Sectoral Sanctions Identifications, Foreign Sanctions Evaders.
  • EU Consolidated Financial Sanctions List (Common Foreign and Security Policy).
  • UK HM Treasury Consolidated List of Financial Sanctions Targets.
  • UN Security Council Consolidated Sanctions List.
  • Australia DFAT Consolidated Sanctions List.
  • Canada OSFI Consolidated Sanctions List.
  • Per-jurisdiction lists where applicable (e.g. Switzerland SECO, Singapore MAS).
  • OFAC Crypto Sanctions (digital-currency designations).

2. Hit Handling

A confirmed sanctions hit on the organization, an executive, an authorized signer, or a beneficial owner is a hard block that prevents application progression and triggers immediate review. The Platform records the hit, source list, similarity score, and screening timestamp. Foundations are notified.

3. False Positives

The Platform uses fuzzy-match scoring with a default threshold of 0.85 (Jaro-Winkler with token-aware adjustment). Operations review borderline matches. Foundations may file a false-positive correction request, which is logged and reflected in future screening for the same entity.

4. High-Risk Jurisdictions

Grantees or beneficial owners with country code in IR, KP, SY, CU, RU, BY, VE, MM, or any FATF grey/black-list jurisdiction receive a heightened-review flag. The flag does not auto-block; the Foundation makes the final decision per Doc 01 §4.4.

5. Refresh Cadence

Sanctions data is refreshed daily from Yente / OpenSanctions and from the underlying source lists. Foundations receive notification when an active grant's organization or beneficial owner appears on a list discovered after grant award.