Sanctions & Politically Exposed Persons (PEP) Screening Policy

1. Purpose

To prevent sanctioned individuals, entities, or PEPs from misusing the WITTY platform.

2. Screening Process

WITTY screens users against:

• International sanctions lists (OFAC, UN, EU, UK HMT)
• PEP and adverse media databases
• Lists maintained by licensed financial partners

3. Ongoing Monitoring

Screening is conducted:

• At onboarding
• Periodically thereafter
• When user details materially change

4. Escalation

Confirmed sanctions or PEP risks result in:

• Immediate restriction of access
• Escalation to licensed payment partners
• Termination where required by law

Contact Information

WITTY Technology Limited

Compliance & Support