1. INTRODUCTION
This Restricted Jurisdictions & Sanctions Policy explains the general principles governing international service eligibility and sanctions-related considerations at Verity Forensic Trace.
Verity Forensic Trace is an independent blockchain forensics and digital asset recovery consultancy registered in Liechtenstein.
Registered Address:
Bangarten 21, Vaduz, LiechtensteinOur services include blockchain forensic investigations, cryptocurrency asset tracing, smart contract analysis, cryptocurrency fraud investigations and digital asset recovery advisory.
As digital asset transactions frequently involve multiple jurisdictions, international engagements may raise legal, regulatory and sanctions-related considerations.
This Policy describes our intended approach to assessing those considerations.
2. PURPOSE OF THIS POLICY
The purpose of this Policy is to establish a transparent framework for evaluating international enquiries and potential client engagements.
Its objectives include:
- Recognising applicable sanctions restrictions.
- Identifying potential jurisdictional limitations.
- Supporting appropriate client eligibility assessments.
- Considering relevant ownership and control relationships.
- Recognising circumstances requiring additional review.
- Avoiding engagements prohibited by applicable law.
- Communicating relevant service restrictions.
This Policy does not replace applicable legislation or mandatory legal requirements.
3. INTERNATIONAL SERVICE AVAILABILITY
Verity Forensic Trace considers enquiries from eligible individuals, businesses, legal professionals and institutional organisations internationally.
However, international availability does not mean that every service can be provided in every jurisdiction.
Eligibility may depend on:
Client Location
The country or territory associated with the client.
Relevant Parties
The individuals and organisations involved in the proposed engagement.
Nature of Services
The specific investigative or advisory activities requested.
Applicable Restrictions
Sanctions, regulatory requirements and other legal limitations.
Payment Arrangements
Relevant restrictions affecting proposed payments or financial relationships.
Professional Considerations
The Company’s ability to undertake the engagement lawfully and appropriately.
The Company may decline or discontinue an engagement where applicable restrictions prevent it from proceeding.
4. APPLICABLE SANCTIONS FRAMEWORKS
International sanctions may be imposed by governments and international organisations.
Depending on the circumstances, relevant frameworks may include:
Liechtenstein Sanctions Requirements
Applicable sanctions and implementing measures under Liechtenstein law.
United Nations Sanctions
Relevant sanctions adopted through the United Nations Security Council.
European Union Sanctions
EU restrictive measures where applicable to the relevant parties, activities or jurisdictions.
United States Sanctions
US sanctions where a relevant jurisdictional connection exists.
United Kingdom Sanctions
UK sanctions where applicable to the relevant engagement.
Other Applicable Restrictions
Additional national or international requirements that may apply to particular transactions or parties.
The applicability of a sanctions framework depends on the relevant legal circumstances.
5. RESTRICTED JURISDICTIONS
Certain jurisdictions or territories may be subject to broad sanctions restrictions or other limitations affecting the provision of services.
The Company may restrict services where required by applicable law or under a separately adopted internal risk policy.
Potentially relevant jurisdictions and territories may include those subject to extensive sanctions measures, such as:
- Iran
- North Korea
- Cuba
- Russia
- Belarus
- Crimea
- Certain territories of Ukraine subject to territorial sanctions
Important clarification:
The inclusion of a jurisdiction in this section does not mean that every individual or organisation located there is automatically prohibited from receiving all services.
Sanctions differ by jurisdiction, activity, person and applicable legal framework.
The Company’s final restricted-jurisdictions list must be established according to applicable requirements and its approved internal policy.
Approved Restricted Jurisdictions List: [To Be Confirmed]
6. ENHANCED DUE DILIGENCE JURISDICTIONS
Certain jurisdictions may require additional consideration because of sanctions exposure, financial crime risks or other relevant circumstances.
Examples that may warrant further assessment include:
- Afghanistan
- Myanmar
- Syria
- Venezuela
- Sudan
- South Sudan
- Yemen
- Libya
- Somalia
- Lebanon
- Iraq
- Nicaragua
- Democratic Republic of the Congo
- Central African Republic
These examples are not a definitive legal classification or a statement that all persons in these countries are subject to sanctions.
Enhanced due diligence may be appropriate depending on the specific circumstances.
Approved Enhanced Due Diligence Criteria: [To Be Confirmed]
7. DESIGNATED PERSONS & ORGANISATIONS
Sanctions restrictions may apply to particular individuals, organisations or other designated parties.
Relevant considerations may include:
Individual Designations
Persons identified under applicable sanctions regimes.
Corporate Designations
Companies and other organisations subject to relevant restrictions.
Ownership Relationships
Entities owned by designated persons where applicable sanctions rules extend to such ownership.
Control Relationships
Entities controlled by designated persons where relevant legal restrictions apply.
Associated Parties
Other parties whose involvement may affect the legality of an engagement.
A person’s nationality or residence alone does not necessarily establish that they are sanctioned.
8. CLIENT IDENTIFICATION & SCREENING
Depending on the circumstances, client eligibility assessments may involve reviewing relevant identifying information.
Such information may include:
- Full legal name.
- Country of residence.
- Nationality where relevant.
- Corporate registration details.
- Relevant ownership information.
- Authorised representative details.
- Nature of the proposed engagement.
- Relevant transaction information.
The scope of screening depends on applicable legal obligations and the circumstances of the matter.
9. CORPORATE OWNERSHIP & BENEFICIAL OWNERS
Corporate engagements may require consideration of relevant ownership and control relationships.
Depending on applicable requirements, the assessment may involve:
Legal Entity Identification
Identifying the relevant organisation.
Registration Information
Reviewing relevant corporate details.
Ownership Structure
Understanding material ownership relationships.
Beneficial Ownership
Identifying relevant natural persons where legally required or otherwise appropriate.
Control Relationships
Assessing relevant control arrangements.
Authorised Representatives
Confirming the authority of individuals acting on behalf of an organisation.
Ownership and control restrictions must be assessed according to the applicable sanctions framework.
10. TRANSACTION-RELATED SANCTIONS CONSIDERATIONS
Certain engagements may involve cryptocurrency transactions or financial arrangements connected with sanctioned parties or restricted activities.
Relevant considerations may include:
Digital Asset Transactions
The nature and context of relevant cryptocurrency transfers.
Identifiable Service Providers
Potential involvement of relevant exchanges, custodians or other digital asset services.
Sanctioned Counterparties
Transactions involving parties subject to applicable restrictions.
Restricted Economic Activities
Activities prohibited under relevant sanctions frameworks.
Payment Arrangements
Proposed payment methods or financial relationships that may raise sanctions considerations.
Professional Services
Restrictions affecting the provision of particular advisory or technical services.
The presence of a cryptocurrency transaction involving a restricted jurisdiction does not automatically establish a sanctions violation.
11. ENHANCED DUE DILIGENCE
Where appropriate, additional information may be requested before accepting or continuing an engagement.
This may include:
- Additional identity information.
- Corporate ownership documentation.
- Clarification of relevant parties.
- Information about the purpose of the engagement.
- Relevant transaction documentation.
- Additional jurisdictional information.
- Professional or legal clarification.
Enhanced due diligence should be proportionate to the circumstances and applicable requirements.
12. CLIENT ELIGIBILITY DECISIONS
Following an appropriate assessment, the Company may determine that an enquiry:
Is Eligible for Consideration
No identified restriction prevents the proposed engagement from proceeding, subject to other acceptance criteria.
Requires Additional Review
Further information or professional assessment is necessary.
Cannot Be Accepted
Applicable restrictions or other legitimate considerations prevent the engagement.
Eligibility decisions should be based on relevant information and applicable requirements.
13. CHANGES IN CLIENT CIRCUMSTANCES
Relevant circumstances may change during a professional engagement.
Examples include:
- Changes in client location.
- Changes in corporate ownership.
- New sanctions designations.
- Changes in applicable law.
- New information concerning relevant parties.
- Changes in the nature of the requested services.
Where necessary, the Company may reassess an engagement.
Any suspension or termination must be handled according to applicable law and relevant contractual conditions.
14. THIRD-PARTY PROFESSIONAL INVOLVEMENT
Certain matters may require assistance from external professionals.
These may include qualified legal advisers or other appropriately authorised specialists.
Third-party involvement does not remove the Company’s responsibility to consider applicable restrictions.
Information sharing must comply with relevant legal and confidentiality requirements.
15. INTERNATIONAL PAYMENTS
Professional services may involve payments under agreed engagement terms.
Payment arrangements must comply with applicable legal requirements.
Certain financial institutions, payment providers or digital asset services may impose additional restrictions.
The Company does not guarantee that a particular payment method will be available in every jurisdiction.
Payment arrangements must not be structured to circumvent applicable sanctions or other legal restrictions.
16. PROHIBITION ON SANCTIONS EVASION
The Company does not knowingly undertake engagements intended to circumvent applicable sanctions.
Clients must not use the Company’s services to conceal prohibited activities or misrepresent relevant parties.
Attempts to evade applicable restrictions may result in an engagement being declined or discontinued, subject to legal and contractual requirements.
17. DATA PROTECTION & CLIENT INFORMATION
Information collected during eligibility assessments may constitute personal data.
Such information must be processed according to applicable data-protection requirements.
The Company recognises the importance of:
- Lawful processing.
- Purpose limitation.
- Data minimisation.
- Appropriate access.
- Confidentiality.
- Responsible retention.
Further information is provided in the Privacy Policy.
18. POLICY REVIEW & UPDATES
Sanctions requirements may change over time.
New designations, amendments or legal developments may affect the availability of services.
The Company should review relevant requirements and update its internal procedures where necessary.
This Policy may be amended to reflect changes in applicable law, service activities or approved internal restrictions.
19. LIMITATIONS OF THIS POLICY
This Policy provides general information about international service eligibility and sanctions-related considerations.
It does not constitute legal advice.
It does not provide an exhaustive list of all applicable sanctions measures.
The applicability of particular restrictions depends on the relevant circumstances and legal framework.
Where necessary, specific matters should be referred for qualified legal review.
21. CONTACT INFORMATION
For enquiries concerning international service eligibility:
Verity Forensic Trace
Email: [Official Company Email]
Website: https://vftrace.com
22. FINAL INFORMATION
Verity Forensic Trace provides independent blockchain forensic investigations and digital asset recovery advisory services to eligible international clients.
The availability of services depends on applicable laws, sanctions restrictions, regulatory requirements and the circumstances of the proposed engagement.
The Company may decline engagements where relevant restrictions prevent it from proceeding.
Document Status: Draft — Subject to Compliance Review
Version: 1.0