Sanctions Compliance Policy

1. Applicable Sanctions Regimes

• United Nations Security Council (UNSC) Sanctions Committee
• Office of Foreign Assets Control (OFAC) — United States Department of the Treasury
• European Union Consolidated List of Financial Sanctions
• UK Office of Financial Sanctions Implementation (OFSI)
• UAE Executive Office for Control and Non-Proliferation (EOCN)
• Other national and regional sanctions bodies relevant to our operating jurisdictions

2. Screening Programme

All counterparties, beneficial owners, directors, and key personnel are screened against global sanctions lists prior to onboarding and on an ongoing basis. Screening is conducted using a commercially licensed sanctions screening platform with daily list updates.

3. Jurisdiction Risk

KGML does not engage in transactions that directly or indirectly involve sanctioned countries, territories, or governments. We apply heightened scrutiny to transactions with jurisdictions identified as high-risk by OFAC, the EU, or FATF.

4. Blocked Transactions

Where a sanctions hit is identified, the relevant transaction is immediately blocked pending review. Confirmed matches result in rejection of the business relationship and, where required, notification to the relevant sanctions authority.

5. Record Keeping

All sanctions screening records, hit reviews, and compliance decisions are documented and retained for a minimum of five years.