Sanctioned Countries

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Sanctioned Countries Policy

Last Updated: December 22, 2025

Efficient Consulting & Management Inc. (ECM) maintains a strict sanctions compliance policy to protect the integrity of our firm, our clients, and the financial systems within which we operate. As part of our compliance-first approach, we do not provide services to, or engage in transactions with, countries, individuals, entities, or financial institutions that are subject to comprehensive sanctions or equivalent restrictions under applicable sanctions regimes.

Economic sanctions are legal measures imposed by sovereign states or multilateral bodies to promote compliance with international law, protect national security, and advance foreign policy objectives. They may include trade embargoes, asset freezes, financial prohibitions, restricted party listings, and sector-specific restrictions.

Sanctions programs reviewed within ECM’s compliance structure include, where applicable, sanctions administered by the United States through the Office of Foreign Assets Control (OFAC), the European Union’s restrictive measures, United Nations Security Council sanctions, and any other sanctions or trade restrictions relevant to a transaction or jurisdiction.

ECM will not engage in, support, or facilitate any transaction or advisory engagement involving comprehensively sanctioned countries or prohibited parties. ECM will not provide services to individuals, entities, or financial institutions that appear on restricted or blocked party lists unless authorized by law. ECM does not participate in any structure or arrangement intended to bypass or circumvent sanctions requirements.

All engagements with ECM are subject to sanctions screening as part of our onboarding and due diligence procedures. Prospects and clients must provide full and accurate information regarding their identity, beneficial ownership, and transaction purpose to enable proper sanctions assessment.

ECM consults official sanctions lists and government publications, including those issued by OFAC, the United Nations, and the European Union. For the most current sanctions information, clients are encouraged to refer directly to the issuing authorities.

Violations of applicable sanctions laws may result in severe legal, regulatory, financial, and reputational consequences. ECM reserves the right to decline, suspend, or terminate any engagement where sanctions risk cannot be mitigated or where compliance obligations cannot be satisfied.

For questions or clarification regarding this policy, please contact ECM’s compliance team at ssb@ecmbb.com.

Efficient Consulting & Management Inc.

Barbados-based. Compliance-first. Globally active.

This page provides general information only and does not constitute legal, financial, or investment advice.