Sanctions Policy

Sanctions are restrictions on activity imposed, for various reasons on targeted countries, governments, entities, individuals and industries, by bodies such as the United Nations (UN), the European Union (EU), individual countries or groups of countries.

The Masengo Foundation (“MF“) must comply with the legal and regulatory obligations in all the jurisdictions in which we operate. In addition, in order to protect our reputation and other legitimate business interests, in certain circumstances, MF’s sanctions risk appetite may be stricter than our legal obligations.

Together, the MF Sanctions programme, is designed to work harmoniously with the Anti-Money Laundering Policy and associated Sanctions Standard is designed to ensure that MF and its employees know how to identify and manage the legal, regulatory, and reputational risks associated with sanctions, including the risk of MF’s services being used to contravene sanctions.

To achieve this, the MF Sanctions programme incorporates a framework of systems and controls to ensure compliance with all applicable sanctions regulations by MF and its Group legal entities. This includes controls relating to: –

  • roles and responsibilities;
  • compliance with applicable laws and regulations;
  • risk assessments;
  • employee training;
  • payment, customer and employee screening;
  • escalation processes;
  • controls testing; and,
  • independent testing.