Sanctions Policy

Sanctions Policy

Objective:
Zero Emissions World (ZEW) is committed to ensuring full compliance with sanctions regulations to prevent engaging with individuals, organizations, or entities subject to international sanctions. This policy outlines ZEW’s procedures for screening customers and transactions, freezing funds and assets, and reporting any potential violations.

Legal Framework:
ZEW complies with relevant national and international sanctions regulations, including but not limited to:

• EU Regulations: Regulation (EC) No 2580/2001 and subsequent updates regulating sanctions on terrorist financing and asset freezes.

• UN Sanctions: United Nations Security Council Resolutions on individuals and entities involved in terrorism or illicit activities.

• Local Portuguese Legislation: Compliance with Portuguese Law No. 83/2017, which implements EU regulations on combating money laundering and terrorist financing.

• OFAC Sanctions: Adherence to sanctions from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).

Procedures:

1. Sanctions Screening:

• ZEW will screen all donors, NGOs, and recipients of funds against relevant sanctions lists, such as:

  • EU Sanctions List

  • UN Sanctions List

  • OFAC Specially Designated Nationals (SDN) List

  • Other relevant national and international sanctions lists as applicable.

• Screening of Transactions:
  All transactions, including donations and fund transfers, will be screened at the time of donation and during subsequent transactions to detect any potential links to sanctioned individuals or entities.
  

2. Freezing of Funds and Assets:

• Immediate Freezing of Funds:
  If a transaction or partnership involves an individual or entity listed on a sanctions list, ZEW will immediately freeze any funds or assets related to that individual or entity.

• Asset Freeze:
  ZEW will not allow any assets or funds belonging to sanctioned parties (such as oligarchs, terrorist organizations, or entities involved in illicit activities) to be used for campaigns or transferred to NGOs or other recipients.

• Prohibited Transactions:
  ZEW will block or refuse to process any donations that are connected to sanctioned parties or jurisdictions.
  

3. Reporting Violations:

• Suspicious Activity Reporting:
  If ZEW detects any potential violation of sanctions, the situation will be reported to the Portuguese Financial Intelligence Unit (GIF/PJ) or other relevant authorities as required by Law No. 83/2017 and EU Regulations.

• Cooperation with Authorities:
  ZEW will cooperate fully with national and international authorities in investigating and addressing sanctions violations. ZEW will share all relevant information and documentation related to the suspected violation to assist authorities in their investigations.
  

4. Due Diligence and Enhanced Screening:

• Enhanced Due Diligence (EDD):
  ZEW will apply Enhanced Due Diligence (EDD) procedures when dealing with partners, donors, or entities from high-risk jurisdictions or regions subject to comprehensive sanctions. This includes countries like Iran, North Korea, Syria, Cuba, and regions like the Crimea, Donetsk, and Luhansk.

• Screening of Complex or Opaque Entities:
  Donations or transactions involving opaque legal structures or shell companies will be subject to further scrutiny and verification.
  

5. Sanctions List Updates:

• ZEW will regularly update its sanctions screening process to reflect any changes or additions to sanctions lists provided by the EU, UN, OFAC, or other relevant bodies.

• Automatic Screening Tools:
  ZEW will implement automated systems for continuous monitoring of donations, ensuring compliance with updated sanctions lists.
  

6. Reporting and Documentation:

• ZEW will maintain thorough records of all sanctions screenings, including information on transactions that were blocked or delayed due to sanctions issues.

• Documentation of Sanctions Violations:
  Any instance of non-compliance will be documented, and a report will be submitted to the appropriate regulatory body, detailing the nature of the violation and the steps taken to mitigate the issue.
  

7. Awareness:

• Awareness Program:
  ZEW will promote a culture of "zero tolerance" for violating sanctions, ensuring that all team members are well-informed about their roles in preventing prohibited transactions.
  

8. Review of the Sanctions Policy:

• Annual Review:
  This policy will be reviewed annually and updated as needed to reflect any changes in sanctions regulations, operational risks, or internal policies. The review will ensure that ZEW remains compliant with all national and international laws and best practices related to sanctions.

Commitment:

Zero Emissions World is committed to maintaining the highest standards of integrity, transparency, and compliance with international sanctions regulations. By adhering to this policy, ZEW ensures that all donations and partnerships are free from involvement with sanctioned individuals or entities, furthering the mission of combating climate change while maintaining public trust and legal compliance.