Sanctions policy v. 01

5. Sanctions and Cross-Border Compliance Policy

5.1 Screening

Before completing any Tier 2 or Tier 3 transaction (Section 2.2), and periodically for repeat customers, the counterparty's name is checked against:

• The U.S. Treasury OFAC Specially Designated Nationals (SDN) and Consolidated Sanctions Lists;
• United Nations Security Council sanctions lists;
• Applicable Turkish sanctions and counter-terrorist-financing designations;
• EU and UK consolidated sanctions lists, where a transaction has an EU/UK nexus.

5.2 Handling a Match

1. A potential match is placed on hold before funds are released or goods delivered;
2. The responsible officer resolves false positives using available identifying details (date of birth, address) before escalating;
3. A confirmed match results in blocking or rejecting the transaction and, where required by law, filing a blocked- transaction or rejected-transaction report with OFAC or the corresponding Turkish authority;
4. No service is knowingly provided to a sanctioned individual, entity, or a country subject to comprehensive U.S., EU, or Turkish sanctions.

5.3 Prohibited Destinations and Instruments

• No shipment of physical artwork to, and no digital-product delivery knowingly directed to, a comprehensively sanctioned jurisdiction;
• No acceptance of payment instruments that cannot be traced to an identifiable payer at Tier 2/3 thresholds;
• Export of physical artwork otherwise complies with applicable U.S. and Turkish export-control and customs requirements.