Sanctions Policy

As a global service provider, Licensium operates internationally, offering our services to clients worldwide. It is crucial for us to adhere to economic sanctions and trade embargoes imposed by various authorities, including but not limited to the European Union (EU), the United Nations (UN), and other international, supranational, and domestic regulatory bodies. Compliance with the sanctions regimes of the EU and UN is mandatory; additionally, we also ensure compliance with sanctions enacted by other regimes such as the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), the UK’s His Majesty’s Treasury, and other sanctioning authorities.

In line with our Terms of Service, it is your sole responsibility to ensure compliance with relevant economic sanctions and trade embargoes, particularly those enforced by the EU, the UN, and other applicable bodies. We do not provide services to individuals or entities subject to sanctions or embargoes, and we will refuse service to any person or organization seeking to bypass or violate these sanctions. Furthermore, we will cease cooperation with any individual or entity suspected of such practices.

Detailed information on applicable sanctions and embargo regimes can be found via the links below:

• European Union Sanctions: [EU Sanctions Map]

• United States Sanctions (OFAC): [OFAC Website]

• United Kingdom Sanctions: [UK Sanctions List]

• UN Sanctions: [UN Sanctions List]

Before engaging in any business activity involving the sale or supply of goods or services to sanctioned jurisdictions, you are advised to review the relevant sanctions and comply with them.

The following activities will result in our refusal to provide services due to violations or attempts to circumvent sanctions:

• In relation to sanctions imposed following Russia’s military actions against Ukraine:

o Sale, transfer, export, or offering goods, services, or products to individuals or entities in Russia, particularly those covered by the EU’s restrictive measures such as Council Regulation (EU) No 833/2014.

o Import of goods from Russia that generate significant revenue for the country, as outlined in EU regulations.

o Export of luxury goods to Russia and Belarus.

o Trade in dual-use goods and technologies with Russia and Belarus.

• In relation to sanctions against Belarus for its involvement in Russia’s actions:

o Trade activities involving goods or services prohibited by the EU’s restrictive measures, including Council Decision 2012/642/CFSP.

• In relation to sanctions against North Korea (DPRK):

o Transactions involving goods, services, or products subject to sanctions against North Korea.

• In relation to sanctions against Iran:

o Export of dual-use goods, goods used in enrichment-related activities, and certain chemicals, as well as the sale of goods and equipment that may contribute to internal repression.

• Other Transactions:

o Any transactions with individuals or entities listed on the EU, UN, or other international sanctions lists.

This list is non-exhaustive, and you are encouraged to seek legal advice or consult relevant legal documents before engaging in any business activity with sanctioned jurisdictions.

If we suspect that you are operating from a sanctioned country or engaging in prohibited trade, we may, at our discretion, suspend or terminate services to you. We may also request documentation to verify the destination of your goods or services and to assess the potential risk of sanction violations.

We reserve the right to immediately terminate any client relationship if we believe or suspect that the client is violating sanctions or engaging in practices that circumvent sanctions imposed by international, supranational, or domestic authorities. We are committed to reporting any suspected violations to relevant authorities, including law enforcement, regulatory bodies, and government agencies.

Sanctions and embargoes are subject to frequent changes, and countries may implement national sanction regimes. It is crucial to stay informed about the evolving landscape of international sanctions, including those from OFAC, the UK, and the EU.

Some of our third-party partners and service providers may have their own compliance policies regarding sanctions, and they may make independent decisions about their business relationships with you. These decisions are beyond our control and are not influenced by Licensium.

For further information on sanctions, we recommend reviewing resources from the following:

• Sanctions Following Russia’s Military Actions Against Ukraine

• Estonian Tax and Customs Board on Prohibited Goods

• Restrictive Measures Against Iran

• Restrictive Measures Against North Korea

• Restrictive Measures Against Belarus

• Free Sanction List Search Tools

By engaging with Licensium’s services, you agree to comply with this policy and all relevant sanctions regulations. Should you have any questions or need clarification, please consult legal counsel or contact us for further assistance.