Sanctions Compliance Policy

1. Purpose

This Sanctions Compliance Policy describes the measures implemented by Double J Global Pte. Ltd. ("Double J Global", "the Company") to prevent its services from being used in connection with individuals, entities, or jurisdictions subject to international sanctions.

Double J Global is committed to conducting business in accordance with applicable laws and internationally recognized sanctions regimes.

2. Business Model

Double J Global operates as a Merchant of Record (MoR) for certain digital platforms.

The Company processes payments for digital services or platform-based products offered by partner platforms.

Double J Global does not operate as:

• a financial institution
• a remittance service provider
• a cryptocurrency exchange
• a payment service provider

Payments are processed through licensed payment processors.

3. Sanctions Compliance Commitment

Double J Global maintains internal procedures designed to reduce the risk that its services could be used by sanctioned individuals or entities.

These procedures may include:

• sanctions screening procedures
• transaction monitoring
• internal compliance review where necessary

4. Sanctions Lists

Where appropriate, Double J Global may conduct screening against internationally recognized sanctions lists, including those published by:

• United Nations Security Council (UN)
• Office of Foreign Assets Control (OFAC)
• European Union sanctions lists
• other applicable regulatory authorities

5. Restricted Parties

Double J Global does not knowingly provide services to:

• individuals or entities listed on applicable sanctions lists
• parties acting on behalf of sanctioned persons
• organizations involved in prohibited activities under international sanctions frameworks

6. Restricted Jurisdictions

Double J Global may restrict transactions involving jurisdictions that are subject to comprehensive international sanctions.

If a transaction appears to involve a restricted jurisdiction, the Company may refuse or suspend the transaction.

7. Transaction Monitoring

Transactions may be reviewed where risk indicators are identified, including:

• unusually large transactions
• inconsistent customer information
• transactions involving higher-risk jurisdictions

Where necessary, additional verification may be requested.

8. Compliance Actions

If potential sanctions-related concerns arise, Double J Global may take appropriate action, including:

• delaying or refusing transactions
• requesting additional verification
• suspending services
• notifying payment processors or relevant authorities where legally required

9. Internal Controls

Double J Global maintains internal compliance procedures designed to support sanctions risk management.

These procedures may include:

• sanctions awareness measures
• internal transaction monitoring
• review of higher-risk transactions

10. Policy Updates

This Sanctions Compliance Policy may be updated periodically to reflect regulatory developments or operational changes.

The latest version may be published on the company website.

11. Contact

For questions regarding this policy, please contact: