General Sanctions Program
Sinnamas Investment Bank & Capital Trust ("SINNAMAS"), including all its subsidiaries and their branches ("SINNAMAS ENTITIES"), and their employees and contingent workers ("EMPLOYEES"), wherever located, must comply with sanctions legally applicable to them in the jurisdictions in which they are located or do business. In the U.S., such sanctions include those administered and enforced by the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) and any other related U.S. laws and regulatory requirements (the "U.S. Sanctions"). SINNAMAS ENTITIES and its EMPLOYEES are also subject to additional prohibitions based on the non-U.S. sanctions in effect in the jurisdictions in which they are located.
The Firm has established a General Sanctions Program ("GSP") consisting of the following elements: (i) procedures, systems, and internal controls designed to comply with applicable sanctions;(i) a designated person responsible for the day-to-day implementation and operation of the GSP; (iii) independent testing; (iv) an ongoing training program; and (v) reporting and recordkeeping. GSP is personally headed by the Group Chief Executive Officer, Dato Seri Jinison.
Under the OFAC regulations, SINNAMAS ENTITIES and its EMPLOYEES are prohibited from engaging in transactions involving Specially Designated Nationals ("SDNs") and other activities such as:
opening or maintaining accounts for SDNs or any other person subject to prohibitions of U.S. Sanctions;
conducting transactions either directly or indirectly with SDNs or any other person, entity or country prohibited by U.S. Sanctions;
facilitating any prohibited transaction by advising on ways to avoid U.S. Sanctions; or
facilitating any non-U.S. person to engage in transactions prohibited by U.S. Sanctions.
In order to prevent dealings with sanctioned parties, SINNAMAS requires screening of customer relationships and transactions against the SDN list or other legally applicable sanctions lists, including those published or administered by the European Union and Her Majesty's Treasury of the United Kingdom. SINNAMAS has adopted policies and procedures governing the maintenance of its screening systems and processes.