OFAC Sanctions Policy
A risk-based framework for complying with applicable U.S. economic and trade sanctions.
This policy sets required company standards. A product may be offered only when its applicable controls and provider arrangements are in place. It does not replace product-specific agreements or mandatory legal rights.
Scope and accountability
As a U.S.-registered company, Turi Ventures LLC requires its activities and relevant staff and representatives to comply with applicable U.S. sanctions administered by the Office of Foreign Assets Control. Other applicable restrictions and provider requirements must also be assessed. Management must assign a sanctions owner, supply resources, and ensure that a commercial objective does not override a legal restriction.
Risk assessment and coverage
Assessment must address customer and beneficial-owner exposure, counterparties, recipients, payment intermediaries, geographic connections, products, delivery channels, and digital asset activity. Applicable sanctions may be comprehensive, targeted, or limited to specific activities. The company must use current legal information and relevant lists rather than treating every national of a country as prohibited or relying on a permanently hard-coded country list.
Screening and ongoing changes
Relevant parties must be screened before an affected relationship or transaction is permitted, with rescreening when lists, ownership information, or risk changes. The company must assess available location, payment-routing, and digital asset information as appropriate to the product. Screening services and provider checks must be tested for coverage and timeliness. Unavailable or unreliable screening must trigger a controlled fallback, restriction, or pause rather than an unreviewed bypass.
Ownership and the 50 Percent Rule
Review must consider entities owned, directly or indirectly, 50 percent or more in the aggregate by one or more blocked persons, even if the entity is not separately named on a sanctions list. Relevant ownership chains must be assessed under OFAC guidance. Control or a minority interest may still create a risk requiring review, but must not be treated as automatically meeting the ownership rule without a legal basis.
Possible matches and fair review
A potential match requires prompt review using available identifiers such as date of birth, address, nationality, entity details, and ownership information. A name-only alert must not automatically be treated as a confirmed designation. Staff must preserve the review record and escalate uncertainty. Customers may provide corrections through approved channels, while any necessary hold remains proportionate to the applicable legal and risk requirements.
Blocking, rejecting, and authorized activity
A confirmed restriction must be assessed to determine whether property must be blocked, a transaction rejected, or particular activity otherwise restricted. Blocked property must not be returned, transferred, offset, or released without lawful authorization. Rejecting a prohibited transaction is distinct from blocking property. Any reliance on a general or specific license, exemption, or other authorization requires documented verification of its scope and conditions before action.
Reporting and retention
The responsible party must make required OFAC reports, coordinate with relevant providers, and preserve reporting evidence. Where required by 31 CFR 501.603 and 501.604, blocking and rejection reports are due within 10 business days of the action; annual blocked-property reporting must also be assessed where applicable. Records subject to 31 CFR 501.601 must be kept for the required 10-year period, including the applicable period after blocked property is unblocked. Legal holds and other longer duties take precedence.
Evasion and incident response
Staff must not assist with concealment of ownership, misleading geographic information, routing changes intended to evade sanctions, or fragmented transactions designed to avoid controls. Suspected circumvention or a possible breach must be escalated promptly, with containment, evidence preservation, legal assessment, and evaluation of any required report or voluntary disclosure. Relevant customer communications must be lawful and must not reveal protected investigative information.
Training, testing, and contact
Personnel performing relevant functions must receive role-specific training, and controls must undergo risk-appropriate testing and independent review. Management must track findings and review this policy at least annually and after significant legal or operational changes. For a screening correction or sanctions question, contact support@turipay.com with the subject “Sanctions review.” Do not send sensitive evidence until an approved secure channel is provided.
Company and contact
Turi Ventures LLCRegistered in Wyoming, United States30 North Gould StreetSheridan, WY 82801, United Statessupport@turipay.comFor sensitive evidence, request an approved secure channel before sharing documents.
Reference materials
These official resources provide background. Requirements depend on the product, activity, and applicable law.
Management is responsible for assigning policy ownership, maintaining supporting procedures, reviewing these standards at least annually, and updating them when material requirements change.