OFAC and Sanctions Compliance Policy

Regulatory Basis

Upmos complies with U.S. and international economic sanctions regimes administered by:

• U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), 31 CFR Chapter V, including the Specially Designated Nationals and Blocked Persons (“SDN”) List, the Sectoral Sanctions Identifications (“SSI”) List, the Foreign Sanctions Evaders (“FSE”) List, the Non-SDN Iran Sanctions Act List, and the Non-SDN Palestinian Legislative Council List;
• U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), including the Entity List, the Denied Persons List, and the Unverified List;
• U.S. Department of State‘s Directorate of Defense Trade Controls, including the AECA debarred parties list;
• United Nations Security Council Sanctions;
• European Union Restrictive Measures;
• HM Treasury (UK) Office of Financial Sanctions Implementation (“OFSI”) consolidated list.

Comprehensively Sanctioned Jurisdictions

Upmos blocks all transactions with the following jurisdictions and their inhabitants:

• Cuba
• Iran
• North Korea (DPRK)
• Syria
• Crimea region of Ukraine
• Sevastopol
• So-called “Donetsk People’s Republic” (“DNR”) region of Ukraine
• So-called “Luhansk People’s Republic” (“LNR”) region of Ukraine
• So-called “Kherson People’s Republic” region of Ukraine
• So-called “Zaporizhzhia People’s Republic” region of Ukraine

Transactions with these jurisdictions are blocked at multiple layers, including (i) edge-level geo-filtering by our content-delivery network, (ii) IP-address blocking, (iii) checkout-time billing/shipping-address review, and (iv) post-checkout sanctions screening of every order before fulfillment.

List-Based Sanctions Screening

Every consumer account and every vendor account is screened against the OFAC SDN List, the OFAC SSI List, the BIS Entity List, the UN consolidated list, the EU restrictive measures lists, and the UK OFSI list at the following moments:

• Account creation;
• Major profile updates (legal name, address, beneficial-owner change);
• Every payout request;
• Daily, against any updated list publications;
• Order checkout (cross-checking billing and shipping names/addresses).

A hit triggers automatic suspension and manual review by our Compliance team.

Vendor Sanctions Certification

Every vendor seeking to participate on the Upmos marketplace must, as part of Seller Onboarding & Verification:

1. Certify that neither the vendor, nor any of its owners (whether direct or beneficial) holding 25% or more, nor any of its officers or directors, are designated on any of the lists above;
2. Certify that the vendor does not do business with, or source goods from, any comprehensively sanctioned jurisdiction;
3. Certify that the vendor will not knowingly ship products to a buyer located in a comprehensively sanctioned jurisdiction;
4. Agree to a contractual representation and warranty to that effect for the duration of the marketplace relationship.

Reporting Suspected Violations

Any suspected violation of this Policy should be reported immediately to compliance@upmos.com or via the Upmos Whistleblower Hotline at +1 (713) 555-0188. Upmos investigates every report and, where appropriate, voluntarily discloses to OFAC consistent with OFAC’s voluntary self-disclosure framework (31 CFR § 501.602(d)).

Blocking and Reporting

When Upmos identifies a transaction or property in which an SDN-listed person has an interest, we will block the transaction (or property) and report the blocking to OFAC within ten (10) business days as required by 31 CFR § 501.603. Blocked funds are held in a separate interest-bearing account pending OFAC authorization to release or transfer.

Penalties

OFAC sanctions violations carry serious penalties, including civil penalties of up to $368,136 (as adjusted for inflation) or twice the value of the transaction, whichever is greater, and criminal penalties of up to $1,000,000 and 20 years’ imprisonment per violation. We take compliance seriously and expect our vendors, customers, and employees to do the same.

Training and Recordkeeping

All Upmos employees engaged in payments, fulfillment, vendor onboarding, or trust and safety receive annual sanctions-compliance training. All sanctions-screening records, certifications, and blocking reports are retained for not less than five (5) years from the date of the relevant transaction.

Updates

This Policy is reviewed at least annually and updated whenever there is a material change to any of the underlying sanctions regimes.

Contact

Email: compliance@upmos.com · legal@upmos.com

OFAC: ofac.treasury.gov · Hotline: 1-800-540-6322

How Can You Contact Us About This Policy?

If you have any further questions or comments or wish to report any problematic Content or Contribution, you may contact us by:

General Contact

• Phone: 1(855)637-2433 (Mon–Fri, 7 AM–8 PM CT)
• General Support: support@upmos.com
• Report Issue: upmos.com/report
• Send Feedback: upmos.com/feedback

Department Directory

Mailing Address

Upmos Inc.
9896 Bissonnet St
Houston, TX 77036
United States