Sanctions and Restricted Jurisdictions Policy
1. Purpose
IGMS LTD does not provide services to persons, entities or activities connected with jurisdictions or parties that are subject to sanctions or embargoes, or that we cannot serve lawfully. This policy states the list of restricted jurisdictions and how we apply it.
2. Restricted jurisdictions
| Category | Jurisdictions (starting list) | Rule |
|---|---|---|
| ANot served | Iran; North Korea (DPRK); Cuba; the Crimea, Donetsk and Luhansk regions of Ukraine | No orders, accounts or services. Existing relationships are ended. |
| BOnly with written compliance approval | Russia; Belarus; Syria; Myanmar; Venezuela; Afghanistan; any other jurisdiction on the FATF list of high-risk jurisdictions subject to a call for action | Enhanced due diligence and written approval by the compliance officer, with legal advice where needed. Some IT and hosting services are restricted by sanctions measures; we apply them. |
| CActivity restrictions | Gambling and betting; crypto-asset and payment services | Only licensed operators, only for licensed markets; no services used to offer gambling to persons in Category A or B jurisdictions or in the USA. |
The list is reviewed at least quarterly and whenever sanctions measures change, against the official sources: the EU consolidated sanctions list and Official Journal, the UN Security Council lists, UK OFSI and US OFAC lists, and the FATF publications. Changes are approved by the compliance officer and recorded. Sanctions law changes often; where this policy and the law differ, the law applies.
3. How the restrictions are applied
| Step | What we do |
|---|---|
| Onboarding | We collect the Client's registration details, directors and beneficial owners, identification, billing country and the countries where it operates and serves customers. We screen the company, its directors and beneficial owners against the sanctions lists above. We refuse Category A, and refer Category B to the compliance officer. |
| Order checks | Where the ordering platform supports it, we compare billing country, registration country and the country of the ordering IP address. A mismatch or a high-risk transaction triggers manual review and, if needed, identification documents. |
| Ongoing monitoring | We re-screen active clients at least once a year, at renewal, and when a sanctions list changes materially. We review changes of ownership, address or business activity. |
| Matches and doubts | On a possible match we stop the order or pause the service, escalate to the compliance officer, record the decision and reasons, and report to the competent authority where the law requires. We do not release services until the match is cleared. |
| Contract terms | Clients warrant that they and their customers are not sanctioned and do not serve restricted jurisdictions, and agree that we may suspend or terminate at once for a breach (Terms IGMS.P1, sections 2, 3 and 7). |
| Records | We keep the screening evidence, decisions and approvals for at least the period the law requires (default five years after the relationship ends). |
4. Responsibility
The compliance officer is George Sarris, Director. Questions and reports: hello@igms.com.cy.
This document was last updated on Oct 12, 2026