1.0Purpose
Misc Holdings is committed to ensuring that no person, entity, or transaction within the Group is, directly or indirectly, in breach of any applicable sanctions regime, and that engagement with PEPs is conducted with the heightened scrutiny that the elevated corruption and reputational risk of those relationships requires.
2.0Sanctions regimes
The Group screens against, and complies with, the following sanctions programmes as a baseline:
- U.S. Treasury OFAC — Specially Designated Nationals (SDN) list, Sectoral Sanctions Identifications (SSI) list, and country-based programmes.
- UN Security Council Consolidated Sanctions List.
- EU Council Consolidated Financial Sanctions List.
- UK HM Treasury OFSI Consolidated List of Financial Sanctions Targets.
- Other national sanctions lists as relevant to a counterparty's jurisdiction or transaction.
The Group will not knowingly engage with any individual, entity, or vessel designated under any of the above programmes, and will block or reject transactions where required by applicable law.
3.0PEP definitions
Consistent with FATF guidance, the Group treats the following categories as PEPs:
- Foreign PEPs — individuals entrusted with prominent public functions in a foreign country.
- Domestic PEPs — individuals entrusted with prominent public functions in the United States or the country of the relevant subsidiary.
- International-organisation PEPs — persons entrusted with prominent functions by international organisations.
- RCAs and family members — Relatives and Close Associates of any of the above, screened on the same basis as the principal.
PEP status persists for a minimum of 12 months following the cessation of the relevant public function, and longer where residual influence or risk remains.
4.0Screening practice
When screening occurs
- At onboarding, before any material relationship is established.
- Continuously, against changes to sanctions lists and PEP databases.
- At every periodic review, with frequency determined by risk rating.
- On any material change to counterparty ownership, control, or activity.
Who is screened
- The counterparty itself.
- All ultimate beneficial owners holding 25% or more of equity or voting rights.
- All directors and authorised signatories.
- Persons exercising control by other means, including via shareholder agreements, golden shares, or contractual arrangements.
5.0Match handling
Hits are triaged by the Group MLRO into one of three categories:
- True positive — confirmed match against a sanctioned person, entity, or vessel. Relationship is rejected or terminated, funds are blocked or returned in accordance with applicable law, and the matter is reported to the relevant authority.
- Confirmed PEP — relationship may proceed only with documented enhanced due diligence under the AML & KYC Policy, source-of-wealth verification, and senior-management approval. Relationship is reviewed at least annually.
- False positive — disposition is documented in the counterparty file, with sufficient detail to support audit review.
6.0Senior-management approval
No PEP relationship may be established or continued without the written approval of senior management with the appropriate authority. Foreign PEPs require Compliance & Conduct Committee approval. Confirmed PEP relationships are reported to the Board on a quarterly basis.
7.0Sectoral and indirect sanctions
The Group also considers sectoral sanctions, secondary sanctions, and indirect-exposure scenarios — including dealings that, while not directly with a sanctioned party, could result in sanctions exposure due to ownership, control, or use of sanctioned infrastructure. The 50 Percent Rule and equivalent ownership-aggregation rules of other sanctions regimes are applied.
8.0Records and reporting
Screening evidence, hit-disposition rationales, EDD packs, and approvals are retained for a minimum of seven years. Aggregate metrics — number of screenings, number of true positives, number of PEPs onboarded — are reported to the Compliance & Conduct Committee at each meeting.
9.0Training
Personnel involved in counterparty onboarding, transaction processing, or compliance receive sanctions and PEP-screening training annually. Training covers sanctions list reading, the 50 Percent Rule, PEP categorisation, and escalation paths.
10.0Tooling
The Group uses commercial sanctions-screening and PEP-screening data providers with documented update cadences, fuzzy-matching capabilities calibrated to minimise false negatives, and full audit trails. Provider selection is reviewed annually.
Questions about this document should be directed to the Compliance & Conduct Committee at compliance@misc.ltd. This policy is reviewed at least annually and may be updated without notice; the version number above governs.