The International Trade Council (hereinafter referred to as "ITC", "we", "us", or "our") is committed to upholding the highest standards of ethical conduct and compliance with international laws and regulations. Our Blacklist and Sanctions Policy outlines our commitment to not engage with blacklisted or sanctioned entities, their management, personnel, or any affiliated organizations. This policy also clarifies the sources from which we obtain our blacklist information.
This Blacklist and Sanctions Policy applies to all ITC employees, board members, volunteers, representatives, members, and affiliated entities.
We strictly adhere to international sanctions and blacklist regulations and will not engage with or provide services to:
- Blacklisted or sanctioned entities, their managers, or personnel.
- Organizations and/or people that have partnerships, shareholdings, ownership, or affiliations with blacklisted or sanctioned entities.
Sources of Blacklist Information
We obtain blacklist and sanctions information from reliable and authoritative sources, including but not limited to:
- United Nations Security Council Sanctions List.
- United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List.
- European Union Consolidated Financial Sanctions List.
- United Kingdom's Office of Financial Sanctions Implementation (OFSI) Consolidated List of Financial Sanctions Targets.
Compliance and Due Diligence
To ensure compliance with this policy, we will:
- Conduct comprehensive due diligence on our members, partners, and affiliated entities to identify any potential connections with blacklisted or sanctioned entities.
- Regularly review and update our internal blacklist and sanctions database to reflect any changes or additions to the international sanctions lists.
- Provide training and resources to our employees, board members, and volunteers to ensure they understand and adhere to this policy.
Any ITC employee, board member, volunteer, or representative who becomes aware of a potential violation of this policy must promptly report the matter to their supervisor, manager, or designated contact person within the organization.
Consequences of Non-Compliance
Failure to comply with this Blacklist and Sanctions Policy may result in disciplinary action, up to and including termination of employment or association with the ITC. We reserve the right to take any necessary legal action against individuals or entities found to be in breach of this policy.
Changes to this Blacklist and Sanctions Policy
We reserve the right to modify this Blacklist and Sanctions Policy at any time. We will notify you of any changes by posting the updated policy on our website with a new effective date. Your continued association with the ITC after the posting of changes constitutes your acceptance of the updated policy.
If you have any questions or concerns about this Blacklist and Sanctions Policy or our commitment to compliance with international sanctions regulations, please contact us.