Sanctions compliance program
A neutral clearing house is not a neutral venue for sanctioned actors.
- Regulator
- US Treasury · OFAC
- Framework
- OFAC Framework · May 2019
- Violations regime
- IEEPA · TWEA · OFAC 501
- Owner
- Chief Compliance Officer
Commitments
Five commitments. One policy.
- 01
Management commitment
The Board has adopted the sanctions compliance policy, allocated budget and independent authority to the CCO, and receives quarterly reporting on list updates, alert volumes, and escalations. - 02
Risk assessment
Annual sanctions risk assessment covering member geography, resource classes (downlink, ISL, propellant, hosted payload, spectrum), counterparty jurisdictions, and end-use where knowable. Results feed the member-risk model. - 03
Internal controls
Codified in the compliance manual: screening rules, alert handling, blocking and rejection procedures, reporting timelines, and record retention consistent with 31 CFR 501.601. - 04
Testing and auditing
Quarterly internal testing of screening logic, annual external review, and periodic spot-tests of alert disposition files. All findings tracked to closure. - 05
Training
Annual sanctions-specific training for all employees; enhanced training for onboarding, trading-operations, and compliance teams. Board-level sanctions briefing annually. - 06
Root-cause analysis
Every apparent violation or close call is analysed for root cause. Remediation is documented, tracked, and reported to the Risk Committee.
Lists screened
The screened universe.
Screening inventory
- OFAC SDN
- Specially Designated Nationals and Blocked Persons List
Refreshed on publication — typically multiple updates per week.
- OFAC Consolidated
- Non-SDN consolidated sanctions (NS-PLC, FSE-IR, NS-MBS, SSI, CMIC, and related)
Sectoral and non-blocking lists with material compliance obligations.
- CAATSA
- Countering America's Adversaries Through Sanctions Act of 2017, Title II designations
Russia-specific secondary sanctions; applies to certain energy and defence counterparties.
- UN Consolidated
- UN Security Council consolidated sanctions list
Binding on UN Member States; refreshed on issuance.
- EU Consolidated
- Consolidated list of persons, groups, and entities subject to EU financial sanctions
Published by European External Action Service; includes Russia, Belarus, Iran, and others.
- UK OFSI
- UK Consolidated Sanctions List (Office of Financial Sanctions Implementation)
HM Treasury list; binding on UK-nexus transactions.
- Allied lists
- Canada OSFI, Australia DFAT, Switzerland SECO, Singapore MAS
Screened for risk coverage where members or counterparties have exposure.
Embargo jurisdictions
Countries with comprehensive US sanctions.
Comprehensive embargoes
- Iran
- Iranian Transactions and Sanctions Regulations — 31 CFR 560
Comprehensive prohibition on goods, services, and technology; no General Licenses relied upon.
- Cuba
- Cuban Assets Control Regulations — 31 CFR 515
Comprehensive embargo. US persons prohibited from dealings absent specific license.
- North Korea (DPRK)
- North Korea Sanctions Regulations — 31 CFR 510
Comprehensive; secondary sanctions and UN Security Council overlay.
- Syria
- Syrian Sanctions Regulations — 31 CFR 542
Comprehensive prohibition on services and export transactions.
- Russia — sectoral
- Russia-Related Sanctions — 31 CFR 587 · Executive Orders 14024, 14065, 14066, 14068
Sectoral blocking plus Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia regional prohibitions.
- Crimea, DNR, LNR regions
- Comprehensive regional embargo under Executive Order 13685 / 14065
Applies to the Russian-occupied Ukrainian territories.
Screening cadence
Screen everywhere the risk can enter.
- 01
At onboarding
Every legal entity, every beneficial owner identified under BOI, every authorised signatory, and every listed director is screened against the sanctions and PEP inventory before onboarding completes. - 02
On material change
Any CDD refresh, change of beneficial ownership, change of address, change of jurisdiction of operation, or change of control triggers a full re-screen within 24 hours. - 03
On each trade
Before every ORCH match, both legs are re-screened. A positive match blocks the trade and routes the member pair to the compliance analyst queue. - 04
On list publication
Sanctions lists are ingested on publication. Every active member is re-screened against the new list within the OFAC 10-business-day reporting window. - 05
Fuzzy matching
Screening uses both exact match and name-variant fuzzy matching tuned to OFAC's published transliteration norms, with a false-positive rate benchmarked quarterly. - 06
Escalation path
Potential matches are reviewed by two compliance analysts; escalation to CCO within four business hours. True matches result in immediate blocking and OFAC reporting where required.
Reporting and blocking
The mechanics of a block.
Where Wavestar identifies that a property or interest in property of a blocked person is on its books, the property is segregated into a blocked account and reported to OFAC within ten business days of the blocking action, consistent with 31 CFR 501.603. An Annual Report of Blocked Property is filed by 30 September each year covering the preceding fiscal year. Rejected transactions (non- blocked but prohibited) are reported within ten business days.
Principle
Why we are strict.
A clearing house's word is only worth what it costs to break. If we onboard a sanctioned actor, no institutional counterparty will ever trust us again.
Compliance enquiry
Questions about screening exposure?
Prospective members with complex ownership, cross-border affiliates, or allied-jurisdiction footprint can request a pre-onboarding sanctions discussion with the compliance team.