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Export Control & Sanctions Compliance Policy

Clinicians Check Global Group

Last updated: 27/05/2025

Executive Summary

CliniciansCheck operates as a global digital platform and complies with all applicable export control, economic sanctions, and trade restrictions imposed by national and international authorities. This policy outlines how we identify, block, and report activity that may violate export regulations, embargo laws, or trade blacklists.

It is designed to ensure compliance with regulatory bodies including:

  • UK Export Control Joint Unit (ECJU)

  • US Office of Foreign Assets Control (OFAC)

  • European Union Sanctions Regime

  • United Nations Security Council Sanctions Committee

  • Australian Sanctions Office (ASO)

  • Canadian Export and Import Controls Bureau

  • India’s DGFT

All applicable multilateral trade agreements and dual-use export control regimes

1. Scope of Covered Activities

This policy applies to:

  • Digital exports (e.g., AI tools, healthtech software, databases)

  • Financial transactions and revenue streams

  • Remote service delivery (e.g., clinician-patient interactions, digital consultations)

  • Platform usage from or within high-risk jurisdictions

  • Third-party integrations and technology partnerships

  • Shipping or transfer of physical goods (e.g., medical devices, supplements, health-related products)

2. Restricted Jurisdictions & Sanctioned Parties

CliniciansCheck does not allow access to its services, technology, or marketplace in regions subject to:

  • Comprehensive international embargoes

  • Trade sanctions involving health services, digital infrastructure, or dual-use technologies

  • Directives prohibiting exports to certain governments, entities, or individuals

This includes (but is not limited to) restricted activity with:

  • OFAC’s Specially Designated Nationals (SDN) List

  • UN-designated entities or individuals

  • EU and UK consolidated sanctions lists

Sanctioned or embargoed jurisdictions such as (as of latest review):

  • North Korea

  • Iran

  • Syria

  • Crimea (Ukraine)

  • Russia (selected sectors, persons)

  • Belarus (selected sectors)

  • Cuba (with exceptions per US regulations)

3. Internal Controls & Access Prevention

To maintain compliance, CliniciansCheck implements:

Geo-IP restrictions and jurisdiction-based access controls

Sanctions screening for:

  • Users

  • Partners

  • Payments

  • Suppliers

KYC/AML checks on financial transactions and high-risk vendors

Platform warnings and auto-blocking for disallowed transactions or profile creation

We also monitor for masked access attempts via VPNs or proxy servers in flagged jurisdictions.

4. Dual-Use & Sensitive Technology Controls

Any product or service classified as dual-use (civil and military application) is automatically excluded from platform sale or export unless compliant with export licenses.

Examples may include:

  • Diagnostic software with surveillance capabilities

  • AI systems with bio-monitoring features

  • Encryption-enabled communications tools

Such technologies will require:

  • Pre-export classification review

  • Licensing validation

  • Legal documentation and tracking logs

5. Financial & Transactional Controls

We comply with global financial laws that restrict:

  • Payments to/from sanctioned regions

  • Cryptocurrency transactions linked to embargoed wallets or exchanges

  • Trade-based money laundering or sanctioned asset transfers

We work with regulated payment processors who perform real-time sanctions compliance. Suspicious or blocked transactions are flagged for investigation.

6. Incident Response, Reporting & Enforcement

If CliniciansCheck detects or is notified of a possible violation:

  • Access is immediately suspended

  • Internal Compliance & Legal teams investigate

Incidents may be reported to:

  • OFAC (US)

  • ECJU (UK)

  • EU Sanctions Authority

  • UN or local enforcement bodies

Violations may lead to:

  • Account termination

Blacklisting

Legal prosecution or fines for involved parties

7. Training, Audits & Policy Review

Staff involved in global operations, onboarding, payments, AI deployment, or business development undergo annual training on export and sanctions compliance.

This policy is reviewed every 12 months, or immediately in response to:

  • Regulatory changes

  • Geopolitical developments

  • Expansion into new markets

8. Board Oversight & Legal Governance

This policy is enforced under the Board Governance Charter and is integrated into our:

  • Terms of Service

  • Clinician Agreements

  • Vendor Participation Contracts

  • Platform Risk Management Strategy

Clinicians Check Global Group

We are committed to operating as a lawful, globally responsible, and sanctions-compliant organization.