Understanding global sanctions

Convera, and all 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 United Nations (“UN”), the European Union (“EU”), the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”), as well as rules and regulations, as required in the countries, territories, and jurisdictions in which Convera and its subsidiaries operate.

Additionally, even where applicable sanctions laws may permit Convera to process a transaction, 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 or sanctioned jurisdictions or regions. 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 to a client or to a beneficiary 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 currently limits its dealings with certain jurisdictions as set forth below. 

Convera reserves the right to change its policies without notice and reject any transaction in its sole discretion. Convera’s current policies and practices with respect to sanctions are as follows:

Sanctioned Jurisdictions:

North Korea, Cuba and the Crimea, Luhansk and Donetsk Provinces of Ukraine: Convera does not process payments to, from or involving North Korea, Cuba and the Crimea, Luhansk and Donetsk provinces of Ukraine, even if the transactions are deemed legal and authorized by a relevant governing authority.

The Islamic Republic of Iran: Convera does not process transactions involving Iran. However, Convera will process transactions involving Iran for trademark and patent-related services for its US customers, provided that these transactions are within the defined scope of OFAC General License 560.509 and that such transactions do not originate or terminate within the Iranian financial system or do not benefit the Iranian government directly.

The Syrian Arab Republic: 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:

Zaporizhzhia and Kherson regions of Ukraine: Convera will process transactions involving the Ukrainian government-controlled areas of the Zaporizhzhia and Kherson regions. Additionally, Convera will process transactions involving other areas of the Zaporizhzhia and Kherson regions, where it determines such transactions do not involve restricted activities and are authorized under the applicable sanction’s regulatory authority.

Russia and Belarus: Convera may process transactions to/from or involving Russia and Belarus where it determines such transactions are authorized under the applicable sanctions regulatory authority and do not originate or terminate within the Russian and Belarusian financial system. Permissible transactions include, but are not limited to personal remittances, pensions, payroll, and services related to education, such as tuition payments, tuition refunds, housing, and accommodations. Additionally, Convera may process authorized transactions to/ from or involving Russia related to patent and trademark applications and maintenance. Based on company’s internal sanctions policy and risk appetite, Convera retains the right to refuse transactions where a potential prohibited payment activity indirectly involving Russia or Belarus has been identified.

Afghanistan, Yemen, Venezuela: Convera will process transactions involving Afghanistan, Yemen and Venezuela where it determines such transactions are authorized under the applicable sanctions’ regulatory authority. Convera will not process transactions related to the government or state-owned entities, even if the transactions are deemed legal and authorized by a relevant governing authority.

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