Sanctions Watchlist and Screening Policy

Issued by Krepling Inc.

Effective Date: 20th June 2025

1. Purpose

This Sanctions and Watchlist Screening Policy outlines Krepling Inc.’s (“Krepling”) obligations and procedures for screening individuals and entities against sanctions, politically exposed person (PEP), and watchlists as part of our broader Anti-Money Laundering (AML) and Know Your Customer (KYC) program. It ensures compliance with applicable laws and banking partner requirements.

What This Means:

We check names and transactions against official government watchlists to prevent illegal activity.

2. Scope

This policy applies to:

All merchants applying to or using Krepling Pay
All beneficial owners and control persons
All relevant transactions processed through Krepling Pay

What This Means:

We screen everyone involved in your business, including owners, before approving your account.

3. Legal and Regulatory Framework

This policy ensures compliance with:

U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)
European Union Consolidated Financial Sanctions List
United Nations Security Council Sanctions Lists
FinCEN guidance
Sponsor bank mandates (Wells Fargo, Synovus, Deutsche Bank)

What This Means:

We follow U.S. and international rules on screening for terrorism, financial crimes, and restricted individuals.

4. Watchlists Monitored

Krepling screens all relevant parties against:

OFAC Specially Designated Nationals (SDN) List
Sectoral Sanctions Identifications (SSI) List
EU Sanctions List
UN Sanctions List
Consolidated Sanctions Lists from major jurisdictions
PEP databases
Other law enforcement and anti-terrorism watchlists

What This Means:

We match all users and businesses against international security lists to prevent illegal use of Krepling Pay.

5. Screening Frequency

Screening is conducted at onboarding and on a recurring basis.
Transactions are monitored in real-time against sanctions rules.
Merchant data is screened periodically and any time updates are made.

What This Means:

We don’t just check once—we screen regularly and in real time.

6. Screening Coverage

We screen the following data points:

Business name and aliases
Beneficial owners and control persons
Transaction counterparties (as applicable)
IP addresses and geographic indicators (for location-based restrictions)

What This Means:

We check names, companies, and transaction details to spot risks.

7. Risk Escalation and Review Process

If a potential match is identified:

The transaction is paused or flagged.
Our compliance team manually reviews the match.
Identity documents may be requested to verify or dismiss the alert.
Confirmed matches result in immediate denial or suspension of services.

What This Means:

If something suspicious is found, we investigate and may suspend the account.

8. Politically Exposed Persons (PEPs)

Krepling screens for PEPs, defined as individuals with high-profile political roles or family/business ties to them. Additional due diligence is required for PEPs and includes:

Source of funds verification
Ongoing transaction monitoring
Approval from senior compliance officers

What This Means:

If you’re politically connected, we’ll ask for more proof of legitimacy.

9. Recordkeeping

Krepling maintains screening logs and documentation for at least 5 years, including:

Search results
Decisions made
Actions taken
Communications with merchants or regulators

What This Means:

We keep track of all screenings and any decisions we make.

10. Use of Technology

Krepling uses industry-leading compliance tools and sanctions screening databases. Automated systems:

Check names in real time
Monitor IP/geographic anomalies
Flag duplicate or evasive entries

What This Means:

We use software to screen everything automatically and catch suspicious activity fast.

11. Training and Awareness

All relevant employees receive annual training on:

How to recognize sanctions exposure
Handling and escalating potential matches
Using screening tools properly

What This Means:

Our team is trained to spot and handle watchlist issues correctly.

12. Non-Compliance Consequences

Failure to comply with sanctions screening may result in:

Immediate account suspension
Freezing of funds
Mandatory reporting to regulators
Permanent ban from Krepling Pay

What This Means:

Violating sanctions rules can lead to account closure and legal action.

13. Contact Information

For compliance inquiries or match reporting, contact: Email: compliance@krepling.com

What This Means:

You can contact our compliance team if you have a match or any questions about screening.