Sanctions Compliance Policy

Company: Tahweel Financial Services LLC and affiliated entities ("Tahweel")

Policy Type: Sanctions Compliance Policy

Effective Date: Jan 6, 2026

Approved by: Executive Management & Compliance Officer

Applies to: All employees, contractors, users, partners, and third-party providers

1. Purpose

This Sanctions Compliance Policy establishes Tahweel’s commitment to comply fully with all applicable international sanctions laws and regulations. Tahweel strictly prohibits the use of its platform by any person, entity, or jurisdiction subject to sanctions imposed by recognized governmental and international authorities.

The purpose of this policy is to:

  • Prevent sanctioned individuals or entities from using Tahweel services
  • Prevent sanctions evasion
  • Ensure compliance with Stripe requirements and global financial standards
  • Protect Tahweel, its partners, and financial institutions from sanctions violations

2. Regulatory Framework and Authorities

Tahweel complies with sanctions imposed by, including but not limited to:

Primary Sanctions Authorities

  • U.S. Department of Treasury – Office of Foreign Assets Control (OFAC)
  • United Nations Security Council Sanctions Lists
  • European Union Sanctions Lists
  • United Kingdom HM Treasury Sanctions List
  • Financial Action Task Force (FATF) High-Risk Jurisdictions

Additional Applicable Authorities

  • Local national sanctions authorities where Tahweel operates
  • Payment processors (Stripe) sanctions requirements
  • Banking partner sanctions requirements

3. Prohibited Users and Transactions

Tahweel strictly prohibits providing services to:

3.1 Sanctioned Individuals

Any individual listed on:

  • OFAC Specially Designated Nationals (SDN) List
  • UN sanctions list
  • EU consolidated sanctions list
  • UK sanctions list

3.2 Sanctioned Entities

Any company or organization:

  • Listed on sanctions lists
  • Owned or controlled by sanctioned individuals
  • Acting on behalf of sanctioned persons

3.3 Sanctioned Jurisdictions

Tahweel prohibits access from comprehensively sanctioned jurisdictions, subject to applicable regulations. This includes jurisdictions subject to full financial sanctions under OFAC, EU, or UN regulations.

4. Screening and Monitoring Controls

Tahweel implements automated and manual sanctions screening controls.

4.1 Customer Screening

Tahweel screens customers using:

  • IP geolocation monitoring
  • Payment authentication screening (via Stripe)
  • Fraud detection tools
  • Risk-based transaction monitoring

4.2 Transaction Screening

Tahweel monitors transactions for:

  • Suspicious payment patterns
  • Sanctioned jurisdiction indicators
  • Fraud indicators

Transactions may be blocked or rejected if sanctions risk is detected.

4.3 Device and Location Monitoring

Tahweel monitors:

  • IP addresses
  • Device fingerprints
  • Geographic location

Access may be blocked from restricted jurisdictions.

5. Payment Processor Sanctions Controls

Tahweel utilizes Stripe as its payment processor. Stripe independently applies sanctions screening, including:

  • OFAC sanctions screening
  • Financial crime monitoring
  • Payment authentication verification

Tahweel complies fully with Stripe sanctions compliance requirements.

6. Third-Party Supplier Sanctions Compliance

Tahweel only procures digital products from authorized suppliers.

Supplier controls include:

  • Supplier verification
  • Commercial agreements
  • Risk assessment

Tahweel does not engage with sanctioned suppliers.

7. Prohibited Activities

The following activities are strictly prohibited:

  • Attempting to use Tahweel from sanctioned jurisdictions
  • Using intermediaries to bypass sanctions
  • Attempting to conceal identity or location
  • Conducting transactions on behalf of sanctioned persons

Violations result in immediate account termination.

8. Enforcement and Actions

If sanctions risk is detected, Tahweel may:

  • Block transactions
  • Suspend accounts
  • Terminate accounts permanently
  • Restrict platform access

Tahweel reserves full discretion to enforce sanctions compliance.

9. Record Keeping

Tahweel maintains records of:

  • Transactions
  • Risk monitoring
  • Fraud and sanctions monitoring logs

Records are retained in accordance with compliance requirements.

10. Internal Responsibilities

Compliance Officer Responsibilities

The Compliance Officer is responsible for:

  • Maintaining sanctions compliance program
  • Monitoring sanctions risks
  • Updating policies as needed

Contact: compliance@tahweel.io

11. Employee Compliance Requirements

All employees must:

  • Follow sanctions compliance procedures
  • Report suspicious activity internally
  • Comply with applicable laws

Failure to comply may result in disciplinary action.

12. Cooperation with Financial Institutions

Tahweel cooperates fully with:

  • Payment providers
  • Banking partners
  • Regulatory authorities where applicable

Tahweel provides documentation when legally required.

13. Risk-Based Compliance Approach

Tahweel applies a risk-based compliance framework appropriate for its business model.

Tahweel operates as a digital goods retailer and does not provide:

  • Bank accounts
  • Stored value accounts
  • Cash withdrawal services

14. Policy Review and Updates

This policy is reviewed regularly and updated when necessary.

15. Compliance Statement

Tahweel maintains strict sanctions compliance controls consistent with:

  • Stripe and other payment providers compliance requirements
  • International sanctions standards
  • Global financial compliance best practices

Tahweel is committed to preventing any use of its platform in violation of sanctions laws.

16. Contact Information

Compliance Officer

Tahweel Financial Services LLC

Email: compliance@tahweel.io

Website: https://tahweel.io