Sanctions Compliance Policy

1. Our Approach

Sparroz Group LTD is committed to complying with applicable economic and financial sanctions laws and to preventing its services from being used to evade sanctions.


2. Sanctions Screening

Depending on the service and assessed risk, we may screen customers, beneficial owners, directors, representatives, counterparties and transaction information against applicable sanctions and restricted-party information.

Our framework places primary emphasis on sanctions applicable under Canadian law. Where relevant to a service, transaction, counterparty or contractual obligation, sanctions information from other applicable jurisdictions may also be considered.


3. Restricted Persons and Jurisdictions

Sparroz Group LTD does not knowingly provide services that would violate applicable sanctions. We may prohibit or restrict services involving:

  • sanctioned or designated persons
  • entities owned or controlled by sanctioned persons
  • prohibited countries, regions or territories
  • prohibited industries, goods or services
  • restricted financial institutions
  • transactions structured to conceal a sanctioned connection


4. Customer Responsibilities

Customers must provide complete and accurate information about identity, beneficial owners, directors, controllers, counterparties, source and destination of funds, countries involved, transaction purpose and any person on whose behalf they act.

Customers must not attempt to avoid screening or restrictions through intermediaries, altered payment details, multiple accounts, false information or other evasive methods.


5. Transaction Review

A potential sanctions match may result in additional verification, requests for documents, delayed processing, rejection of a transaction, restriction of services, blocking where legally required or reporting to an appropriate authority.

A potential match does not necessarily mean that the person or entity is sanctioned. Further review may be conducted to determine whether the information relates to a listed party.


6. No Circumvention

Customers must not use Sparroz services to directly or indirectly circumvent sanctions, asset freezes, export controls or other legal restrictions.


7. Contact

Sanctions-related enquiries may be directed to compliance@sparroz.io.