Understanding global sanctions

Convera and all of its affiliates, are committed to complying with all applicable economic and trade sanctions laws and regulations as required in the countries, territories, and jurisdictions in which Convera operates. Convera’s compliance program includes policies, controls, systems and processes which are designed to ensure compliance with sanctions rules and regulations maintained by, among others, the U.S. Office of Foreign Assets Controls (“OFAC”), the European Union (“EU”), the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”), and the Australian Department of Foreign Affairs and Trade (“DFAT”), as well as rules and regulations in various countries where Convera operates.

As a matter of internal policy, Convera limits transactions involving certain jurisdictions and parties where such business may present unacceptable levels of sanctions-related risk.

Convera systematically screens data associated with its clients and their transactions against names identified on sanctions lists, as well as against terms and descriptors associated with certain sanctioned countries, regions, governments, and other parties. Potential matches are stopped and reviewed by trained analysts to determine whether the transaction involves one or more sanctioned parties.  Depending on the nature of the applicable sanction, transactions may be either rejected, with funds returned to originator of the transaction, or Convera may be required to freeze and hold funds.   

Frozen and rejected transactions are reported to relevant government authorities as required by applicable laws and regulations. In addition, Convera files annual and other periodic reports of frozen assets in its custody.  In general, frozen funds cannot be released or refunded without first obtaining a license or other permission from the appropriate government agency. Convera generally notifies its clients when an account or transaction is frozen or rejected and may advise such parties of the relevant regulator or regulators from whom permission must be sought to obtain a release of the funds or other assets.

Economic and trade sanctions programs administered by OFAC, and other government bodies prohibit or restrict transactions to or from (or dealings with) certain countries, their governments, and in certain circumstances, their nationals. As a result of these prohibitions and restrictions, Convera limits its dealings with certain jurisdictions as follows:

Sanctioned Jurisdictions:

Iran, North Korea, Cuba and the Crimea, Luhansk and Donetsk Provinces of Ukraine

Convera does not process payments to, from or involving Iran, North Korea, Cuba and the Crimea, Luhansk and Donetsk provinces of Ukraine. Convera screens all transactions against lists of geographic and other terms that may indicate the involvement of these countries or regions and investigates clients and transactions as necessary to prevent any activity that is not lawful or otherwise consistent with Convera’s policies. 

Syria

Convera does not process transactions involving Syria. However, Convera will process transactions involving Syria for trademark and patent-related services for its US customers, provided that these transactions are within the defined scope of OFAC General License 542.520 and do not benefit the Syrian government directly.

In addition, Convera will process transactions involving humanitarian assistance, provided that these transactions are within the defined scope of OFAC General License 542.513, 542.516, 542.522, and other applicable sanctions regimes.

Restricted Jurisdictions:

Zaporizhizhia and Kherson provinces of Ukraine

Convera will process transactions involving Zaporizhzhia and Kherson regions where it determines such transactions are authorized under the sanction’s regimes established by the European Union, Canadian Office of the Superintendent of Financial Institutions, and the Office of Financial Sanctions Implementation of the United Kingdom.

Venezuela

Convera will process transactions involving Venezuela where it determines such transactions are authorized under the applicable sanctions’ regulatory authority; Convera will not process transactions related to the Venezuelan government and/or state-owned entities. However, Convera may process transactions to/from/involving Venezuela related to trademark and patent maintenance and application provided that these transactions are licensed by OFAC.

Russia

Convera does not process transactions to or from Russia. However, Convera may process transactions related to Russian trademark and patent maintenance and application, provided that these transactions are covered by applicable licenses and regulations, including but not limited to those of OFAC, the European Union, United Kingdom and other global sanctions regulators. In addition, Convera may process transactions related to personal remittances, pensions, payroll, and services related to education (including but not limited to tuition payments, tuition refunds, housing, and accommodations). The permitted transactions may not originate or terminate within the Russian financial system.

Afghanistan

Convera may process transactions to, from, or involving Afghanistan where it determines such transactions are covered by applicable General Licenses, including but not limited to General License 14, General License 15, General License 16, General License 17, General License 18, and General License 19.

General License 14 – Authorizing Humanitarian Activities in Afghanistan. General License 15 – Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates in Afghanistan. General License 16 – Authorizing Noncommercial, Personal Remittances to Afghanistan. General License 17 – Authorizing Official Business of the United States Government. General License 18 – Authorizing Official Activities of Certain International Organizations and Other International Entities. General License 19 – Authorizing Certain Transactions in Support of Nongovernmental Organizations’ Activities in Afghanistan.

Belarus

Convera may process transactions to, from, or involving Belarus provided they do not originate or terminate within the Belarusian financial system and do not involve prohibited industries and sanctioned individuals or entities.

Yemen

Convera may process transactions to, from, or involving Yemen where it determines such transactions are covered by applicable general licenses, including but not limited to 31 CFR § 594.518, 31 CFR § 594.519, 31 CFR § 594.520, and 31 CFR § 594.521

*Important note: Convera retains the right to refuse transactions if they are not consistent with the company’s sanctions policy and risk appetite.