Sanctions Policy

Effective: 21 May 2025

1. Introduction

Sanctions are a regulatory mechanism used by governments and international bodies to uphold security, enforce foreign policy objectives, and restrict economic activities with specific individuals, entities, and regions. These restrictions play a crucial role in maintaining global stability and preventing illicit financial transactions.

2. DiviGain’s Commitment to Compliance

DiviGain is committed to full compliance with applicable sanctions laws and regulations in all jurisdictions where it operates. Upholding this policy safeguards our company and clients from financial, legal, and reputational risks while ensuring our continued ability to offer seamless access to global markets.

3. Impact on Business Operations

By adhering to sanctions compliance, DiviGain preserves relationships with market participants, liquidity providers, and business partners. This policy enables us to operate within a secure and compliant framework, ensuring uninterrupted market access and business integrity.

4. Responsibilities of Stakeholders

All individuals and entities affiliated with DiviGain are required to comply with this policy, including but not limited to:

4.1.Members of the Trading Desks and its supporting staff;

4.2.and each party is responsible for ensuring full adherence to the outlined restrictions.

5. Applicable Sanctions Authorities

DiviGain complies with the sanctions laws and regulations set by the following entities, and the restrictions imposed by these authorities are strictly observed in all business dealings, regardless of whether a specific sanction directly applies to a given transaction.

5.1.ASEAN

5.2.Australia

5.3.Cayman Islands

5.4.European Union (Includes independently issued sanctions by Belgium, Germany and the Netherlands outside of the EU framework).

5.5.Hong Kong

5.6.Japan

5.7.Singapore

5.8.Switzerland

5.9.United Kingdom

5.10.United Nations

5.11.United States

6. Automatic Restriction of Sanctioned Countries

To prevent abuse of our system and ensure adherence to international Anti-Money Laundering (AML) regulations, DiviGain automatically adds sanctioned countries to its banned list. Any activity related to jurisdictions subject to sanctions restrictions is prohibited, ensuring robust risk management and compliance with global financial security standards.

7. Prohibited Activities and Compliance Expectations

DiviGain does not engage in any business activities that violate restrictions set forth by international sanctions programs. Additionally, we expect all counterparties and stakeholders to refrain from facilitating transactions that could lead to non-compliance. Any attempts to circumvent sanctions regulations—whether directly or indirectly—will be regarded as a violation of this policy.

8. Enforcement and Protective Actions

DiviGain reserves the right to take necessary steps to protect its interests and those of its clients. In cases where sanctions-related risks arise, DiviGain may implement precautionary measures in accordance with legal frameworks and contractual agreements.

9. Policy Amendments and Updates

This policy is subject to change as global sanctions evolve and DiviGain’s risk considerations adjust. Updates may be implemented at any time without prior notice to ensure ongoing compliance with regulatory developments. Any changes will take effect immediately upon publication on our platform. Users are encouraged to review this policy periodically to stay informed about how we handle relevant obligations. Continued use of our services constitutes acceptance of any updates.

Disclaimer

The information provided in this material is for informational purposes only, and any reliance on it is at the sole discretion of the reader. DiviGain operates as a private, invitation-only club and this website does not constitute a public offering or a solicitation to invest in any regulated financial instrument, security, or fund.Â