Screening

Sanctions, politically exposed person and adverse-media screening for every customer, beneficial owner, controller and authorised party. Each result records the list version, reviewer and timestamp, and follows the Sanctions Policy and the Screening, Monitoring and Source of Funds Policy.

Parties screened

Customers and payment counterparties

Pass

No match on any list

Potential match

Held, escalated to MLRO

Blocked

Held pending MLRO decision

Screening register

List version: ComplyAdvantage (planned) list snapshot 2026-04

Reference	Customer	Type	Result	Category	Reviewer	Checked
100001	David Lipson	Individual	Pass	No match	Asher Freed	20 Apr 2026, 10:00
100002	Netanel Adrai Pagima	Individual	Pass	No match	Asher Freed	20 Apr 2026, 10:00
100003	Reportly Limited	Corporate	Pass	No match	Asher Freed	20 Apr 2026, 10:00
100004	La Lucia LTD	Corporate	Pass	No match	Asher Freed	20 Apr 2026, 10:00
100005	Staff Connect Resourcing Limited	Corporate	Pass	No match	Asher Freed	20 Apr 2026, 10:00
100005	Staff Connect Resourcing Limited	Corporate	Blocked	Sanctions	Trevor Clein	18 Apr 2026, 10:00
100005	Staff Connect Resourcing Limited	Corporate	Potential Match	Adverse media	Trevor Clein	18 Apr 2026, 10:00
100006	QA Test Holdings Ltd	Corporate	Pass	No match	Asher Freed	17 Jul 2026, 12:04
100008	Sentinel QA Global Trading Ltd	Corporate	Pass	No match	Asher Freed	17 Jul 2026, 12:44
100010	Jonathan Blake	Individual	Pass	No match	Asher Freed	17 Jul 2026, 13:28
100012	Jonathan Blake	Individual	Pass	No match	Asher Freed	17 Jul 2026, 13:52
100013	Jonathan Blake	Individual	Pass	No match	Asher Freed	17 Jul 2026, 14:02
100014	Jonathan Blake	Individual	Pass	No match	Asher Freed	17 Jul 2026, 14:07
100015	Viktor Petrov	Individual	Blocked	Sanctions	Trevor Clein	17 Jul 2026, 14:20

How screening is performed

Screening points. Every customer, beneficial owner, controller, director, authorised signatory and relevant counterparty is screened at onboarding, on an ongoing basis, and in connection with relevant transactions and counterparties.
Data quality gate. Onboarding or a payment does not proceed where missing data prevents effective sanctions screening.
Match handling. A potential match is held or blocked pending review. Funds and onboarding approval are not released. Compliance opens a case, records the alert source and matched fields, and carries out triage and enhanced review.
MLRO escalation. Potential true matches, terrorist-property concerns, ownership or control ambiguity and partner-bank alerts are escalated to the MLRO immediately for decision.

Decision categories and controls

Result definitions

PassNo match against sanctions, PEP or adverse-media lists.
Potential MatchHeld pending review and escalated to the MLRO. No release.
BlockedHeld or rejected. Funds not released without MLRO approval.

Scope excluded at launch

ProhibitedPEPsProhibitedCrypto businessProhibitedShell banksProhibitedSanctioned jurisdictions

Every customer and controlling person is screened against sanctions, politically exposed person and adverse-media lists. The list version and the time of the check are recorded against each result.