Sanctions & Export Control Policy – KYC
1. Purpose
This policy establishes the framework to ensure compliance with international sanctions and export control regulations and to prevent unauthorized exports or dealings with sanctioned parties.
Reprodex B.V. commits to complying with all relevant regulations, including sanctions regimes imposed by the European Union and other applicable jurisdictions.
This policy aims to:
- Prevent exports to sanctioned individuals or entities
- Prevent diversion or re-export to sanctioned destinations
- Ensure proper screening of customers and end-users
- Mitigate risks of sanctions circumvention or U-turn transactions
2. Scope
This policy applies to all employees, officers, contractors, subsidiaries, and third parties acting on behalf of Reprodex B.V. It covers exports, re-exports, technology transfers, services, financial transactions and ongoing monitoring.
3. Applicable Regulations
Reprodex B.V. complies with applicable international and national sanctions and export control regimes, including UN sanctions, EU sanctions, and other relevant national export control laws like (e.g. NAFEZA).
4. Roles and Responsibilities
Management provides oversight. Sales manages the program and are responsible for applying screening and compliance checks in their operations.
5. Risk Assessment
Reprodex B.V. performs periodic risk assessments to identify exposure related to geography, customers, products, end use, and distribution channels.
6. Customer Screening
6.1 Initial Screening/ onboarding
Before entering into any transaction or contractual relationship, Reprodex B.V. must screen:
The customer
The beneficial owner (UBO)
Bank involved in the transaction
Screening must be conducted against applicable sanctions lists, including those published by:
the European Union Consolidated List
the Office of Foreign Assets Control (OFAC)
the United Nations Security Council Consolidated List
If a match or potential match occurs, the transaction must be suspended pending review by Management..
6.2 Annual Rescreening Policy
All active customers, distributors, and agents must be re-screened at least once every half year. The Compliance Officer shall:
Maintain a list of active counterparties
Conduct rescreening every 12 months
Document results of each screening
Transactions with parties that become sanctioned must be immediately suspended.
7. Export Classification
Products, software, and technologies must be classified against applicable export control lists to determine whether export licenses are required.
Before export, Reprodex B.V. must determine whether the products:
- Are subject to export control regulations
- Require export licenses
Although copier machines are generally not controlled items, Reprodex B.V. must verify compliance with the EU Dual-Use Regulation administered by the European Commission.
If any controlled components are present, the Compliance Officer must assess licensing requirements.
8. Licensing
Where required, export licenses must be obtained before shipment or transfer of controlled goods or technology.
9. High-Risk Countries and Diversion Risk
Reprodex B.V. must apply enhanced due diligence when exporting to jurisdictions with elevated diversion risk.
Red flags include:
- Requests to ship through third countries
- Incomplete end-user information
- Cash payments or unusual banking routes
- Customers unwilling to sign end-user statements
If diversion risk is suspected, the shipment must be suspended pending investigation.
10. End-User Statement Requirement
For all exports outside the EU, Reprodex B.V. shall obtain a signed End-User Statement confirming:
- The identity of the end-user
- The intended use of the products
- Confirmation that the products will not be re-exported to sanctioned destinations
- The Buyer shall not route the goods through third countries or intermediaries for the purpose of circumventing sanctions or export control regulations.
11. Recordkeeping
All compliance-related documentation including screenings, licenses, and export classifications must be retained according to legal requirements.
12. Training
Employees involved in sales must receive regular sanctions and export control compliance training.