Sanctions Policy of Bellver Markets LLC

1. Purpose
The purpose of this Sanctions Policy is to ensure that Bellver Markets LLC fully complies with all applicable
international sanctions regimes and implements effective measures to prevent sanctioned individuals, entities,
and jurisdictions from accessing the company’s services.

2. Scope
This policy applies to:
- All employees, officers, and agents of Bellver Markets LLC.
- All branches and subsidiaries, both domestic and international.
- All customers, counterparties, and business partners.

3. Legal and Regulatory Framework
Bellver Markets LLC complies with the following international standards and requirements:
- United Nations Security Council sanctions resolutions (binding on all UN member states).
- Financial Action Task Force (FATF) Recommendations on proliferation financing and targeted financial sanctions.
- Wolfsberg Principles on sanctions screening and compliance best practices.

4. Sanctions Compliance Principles
Bellver Markets LLC strictly prohibits entering into or maintaining business relationships with:
- Individuals or entities listed on the UN sanctions lists.
- Persons or entities acting on behalf of, or owned/controlled by, sanctioned parties.
- Citizens or residents of the United States of America.
- Citizens or residents of Georgia.
- Clients or entities from high-risk jurisdictions identified by FATF.

5. Screening and Monitoring
- All customers, beneficial owners, and counterparties are screened against the UN Consolidated Sanctions List prior to onboarding.
- Ongoing monitoring is conducted to detect matches against updated sanctions lists.
- Transactions are monitored for indicators of sanctions evasion or prohibited activity.

6. Reporting Obligations
- Any confirmed or suspected sanctions match must be immediately escalated to the AML/Sanctions Compliance Officer.
- The Compliance Officer will determine whether to block or freeze accounts and ensure that relevant authorities are notified in line with international best practices.

7. Roles and Responsibilities
- Sanctions Compliance Officer: Responsible for maintaining sanctions lists, overseeing screening processes, and reporting to competent authorities where required.
- All Employees: Required to comply with sanctions procedures, report suspected sanctions breaches, and participate in regular training.

8. Training and Awareness
- Employees must undergo sanctions compliance training at least annually.
- Training will include instruction on UN sanctions, customer screening procedures, and red flags for sanctions evasion.

9. Record Keeping
Records of all sanctions screening, monitoring, and reporting activities must be retained for at least five years after the termination of a client relationship.

10. Enforcement and Disciplinary Action
Violations of this Sanctions Policy may result in disciplinary action, including termination of employment and possible legal consequences.

11. Review and Updates
This Sanctions Policy will be reviewed annually and updated as necessary to reflect changes to UN sanctions, FATF recommendations, and international compliance standards.

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Bellver Markets LLC
Omar Khizanishvili Street 264 - Gldani District, Tbilisi, Georgia
+44 7737 2135 84
http://bellver.capital