Sanctions Compliance Policy

This policy describes baseline requirements for sanctions screening, AML/CFT, counter-proliferation financing and high-risk transaction controls for ucake and merchants.

Last updated: 2026-07-03

Policy content

1. Scope and objective

  • This Sanctions Compliance Policy applies to merchants, merchant affiliates, beneficial owners, directors, senior managers, controlling persons, payers, beneficiaries, counterparties, cooperation websites, goods or services and transactions processed or assessed through ucake.
  • The objective is to prevent ucake services from being used in breach of Vietnamese law, United Nations Security Council sanctions, AML/CFT requirements, counter-proliferation financing requirements, bank and payment partner rules or other applicable sanctions requirements.
  • Merchants must not evade sanctions, embargoes or risk controls through transaction splitting, agency arrangements, name changes, third-party accounts, false trade background or similar arrangements.

2. Applicable sanctions and screening scope

  • ucake may screen against Vietnamese law, relevant United Nations sanctions, counter-terrorist financing and counter-proliferation financing requirements, and lists applicable through banks, payment partners and cross-border business.
  • Screening subjects may include individuals, companies, beneficial owners, controllers, directors, payers, beneficiaries, bank accounts, wallets, IP addresses, domains, countries or regions, goods or services, transaction notes and business materials.
  • If a transaction, customer, country, region, good, service or fund flow indicates sanctions, embargo, terrorist financing, proliferation financing, regulatory evasion or high-risk concerns, ucake may request additional information or restrict relevant services.

3. Prohibited conduct

  • Merchants must not transact with sanctioned individuals, entities, vessels, organizations, countries or regions, or directly or indirectly provide funds, goods, services, technical support, accounts, virtual accounts, QR, wallets or payment capabilities to them.
  • Merchants must not process transactions that may breach sanctions, embargoes, export controls, AML/CFT or counter-proliferation financing requirements.
  • Merchants must not evade sanctions review through affiliates, agents, distributors, intermediaries, third-party collection or payout accounts, false orders, altered product descriptions, evasive logistics or routed settlement.
  • Merchants must not knowingly hide or misstate beneficial owners, controlling persons, customer location, transaction purpose, goods or services, source of funds or destination of funds.

4. Merchant information and ongoing commitments

  • Merchants must provide true, accurate and complete information about company, ownership, beneficial owners, controllers, directors, managers, business scope, transaction countries, websites, accounts and partners.
  • Merchants must maintain sanctions screening, customer identification, transaction monitoring, escalation reporting and recordkeeping mechanisms appropriate to their size and risk.
  • If a merchant identifies that a customer, counterparty, order, fund flow, country or region may involve sanctions risk, it must immediately pause the related transaction and notify ucake.
  • Merchants must promptly notify ucake of material changes that may affect sanctions compliance status, including ownership, beneficial owners, business countries, products or regulatory investigations.

5. ucake compliance measures

  • ucake may conduct sanctions and risk screening during onboarding, transaction processing, risk review, dispute handling, monitoring alerts and periodic review.
  • ucake may require merchants to provide additional information, explain transaction background, submit licenses or compliance evidence, update website policies, restrict specific countries or businesses and remediate risk issues.
  • If sanctions hits, suspected sanctions evasion, suspicious transactions, inconsistent documents or material risk are identified, ucake may reject transactions, suspend or terminate services, freeze or delay related requests, retain records and report to competent authorities, banks or partners where required by law.
  • ucake compliance measures do not replace a merchant’s own sanctions compliance obligations; merchants remain independently responsible for ensuring their business and transactions are lawful.

6. Records, cooperation and liability

  • Merchants must keep records sufficient to prove that transactions are lawful, goods or services are genuine, customer identity is clear and source of funds is reasonable, and provide such records upon reasonable request by ucake.
  • Merchants must cooperate with ucake, banks, payment partners and competent authorities in compliance reviews, investigations, document requests and risk handling.
  • Merchants are responsible under applicable law for losses, claims, penalties, investigations, service interruption or third-party liability caused by violating this policy, hiding facts, providing false documents, evading review or engaging in sanctioned activity.
  • This policy may be updated according to sanctions lists, Vietnamese regulatory requirements, international compliance requirements, bank rules and business risk changes.