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Legal

Sanctions Compliance Statement

Ernora Pay
Effective Date: 11.06.2025

1. Introduction

Ernora Pay (“Ernora Pay”, “we”, “our”, or “us”) is committed to complying with all applicable sanctions laws and regulatory requirements. This includes sanctions imposed by the Government of Canada and, where relevant, sanctions measures adopted by international authorities such as the United Nations Security Council (UNSC).

We take our legal, regulatory, and compliance responsibilities seriously and maintain a risk-based sanctions compliance framework designed to prevent transactions, relationships, or activity involving sanctioned persons, entities, jurisdictions, or prohibited sectors.

2. Definitions

“Sanctions” means economic, financial, or trade restrictions imposed by governments or international bodies in relation to specific countries, territories, persons, entities, or sectors.

“Designated Person” means any individual, organization, or entity identified on an applicable sanctions list maintained by Canada or any other authority relevant to our compliance obligations.

“Restricted Jurisdiction” means a country or territory that is subject to broad financial, trade, or economic sanctions.

“Transaction Screening” means the process of reviewing customer data, counterparties, and transaction activity against applicable sanctions lists and risk indicators.

“False Positive” means a potential sanctions match that, after review, is determined not to be an actual match.

3. Legal Framework

Ernora Pay’s sanctions compliance program is designed to support compliance with applicable Canadian laws and regulations, including, where relevant:

  • the Special Economic Measures Act (SEMA);
  • the United Nations Act;
  • the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law);
  • the Freezing Assets of Corrupt Foreign Officials Act.

These legal instruments may prohibit dealings involving sanctioned persons, restricted jurisdictions, blocked property, or prohibited sectors, and may impose disclosure, reporting, or asset-freezing obligations.

4. Our Sanctions Compliance Measures

To support effective sanctions compliance, Ernora Pay applies measures that may include:

  • screening customers, counterparties, and related parties against applicable sanctions lists during onboarding and on an ongoing basis;
  • monitoring transactions for indicators of prohibited or high-risk activity involving designated persons or restricted jurisdictions;
  • updating sanctions data through screening systems and internal compliance controls;
  • escalating and investigating potential matches or suspicious activity;
  • reporting confirmed matches, attempted breaches, or other reportable matters to the appropriate authorities where required by law.

5. Business Restrictions

Ernora Pay does not knowingly engage in, process, or facilitate activity involving:

  • persons or entities subject to applicable sanctions;
  • countries or territories subject to comprehensive restrictions;
  • digital asset wallets, accounts, or financial arrangements known or reasonably suspected to be linked to designated persons;
  • activity connected to sectors that may be subject to sanctions-related prohibitions or restrictions.

We reserve the right to reject, suspend, block, or terminate any transaction, account, or business relationship where we believe sanctions risk may exist or where additional compliance concerns arise.

6. Employee Training and Governance

Relevant staff receive sanctions compliance training appropriate to their role, including guidance on identifying, reviewing, and escalating potential sanctions concerns. Oversight of sanctions compliance is managed within our broader compliance function and supported by both automated screening tools and manual review procedures.

7. Contact and Reporting

If you have any questions regarding our sanctions compliance practices or wish to raise a compliance-related concern, please contact us at:

Ernora Pay
7404 King George Blvd., Suite 200
Surrey, Canada
MSB number: M23468645
Email: support@ernorapay.com

8. Updates

This Sanctions Compliance Statement may be reviewed and updated from time to time in order to reflect changes in applicable laws, regulatory expectations, or Ernora Pay’s business operations.