Sanctions Compliance Policy

Sanctions Compliance Policy

1. Purpose

The purpose of this Sanctions Compliance Policy is to ensure that The Watch Aficionado, including its retail operations and its website thewatchaficionado.com, complies with all applicable U.S. economic and trade sanctions laws and regulations. This policy is designed to prevent the business from engaging in prohibited transactions with sanctioned individuals, entities, countries, or regions.

2. Scope

This policy applies to:

  • The Watch Aficionado retail store operations

  • Online sales and inquiries through thewatchaficionado.com

  • All customers, vendors, and business partners

  • All employees, contractors, and management

  • All payment methods and shipping arrangements

3. Regulatory Framework

The Watch Aficionado complies with sanctions laws and regulations administered by, including but not limited to:

  • U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

  • Applicable provisions of the Bank Secrecy Act (BSA)

  • USA PATRIOT Act

  • Relevant state and federal regulations

4. Sanctions Risk Assessment

The Watch Aficionado maintains a risk-based approach to sanctions compliance, considering factors such as:

  • High-value luxury watch transactions

  • International customers or shipping destinations

  • Cross-border payments or wire transfers

  • Use of third-party intermediaries

5. Prohibited Transactions

The Watch Aficionado strictly prohibits engaging in transactions involving:

  • Individuals or entities listed on OFAC sanctions lists, including the Specially Designated Nationals (SDN) List

  • Countries or regions subject to comprehensive U.S. sanctions

  • Transactions designed to evade or circumvent sanctions requirements

  • Third parties acting on behalf of sanctioned persons or entities

6. Customer and Counterparty Screening

6.1 Screening Procedures

The Watch Aficionado screens customers, vendors, and counterparties, when applicable, against relevant sanctions lists using:

  • Manual checks

  • Payment processor controls

  • Third-party screening tools

6.2 Ongoing Screening

Screening may be conducted:

  • At onboarding

  • Prior to transaction completion

  • When customer risk profiles change

  • When updated sanctions lists are issued

7. Online Sales and Shipping Controls

For transactions conducted through thewatchaficionado.com:

  • Orders involving international shipping are reviewed for sanctions risk

  • IP address, billing address, and shipping destination may be reviewed

  • Orders may be delayed, canceled, or refunded if sanctions concerns arise

8. Escalation and Blocking Procedures

If a potential sanctions match or prohibited transaction is identified:

  • The transaction will be immediately halted

  • Management and the Compliance Officer will be notified

  • Funds or property will be blocked or rejected as required by law

  • Appropriate reports will be filed with OFAC when required

9. Recordkeeping

The Watch Aficionado maintains records related to sanctions screening and compliance actions for a minimum of five (5) years or longer if required by law.

10. Training and Awareness

Employees receive periodic training on:

  • Sanctions laws and obligations

  • Identifying sanctions red flags

  • Proper escalation procedures

  • Confidentiality requirements

11. Compliance Oversight

A designated Compliance Officer is responsible for:

  • Implementing this Sanctions Compliance Policy

  • Monitoring regulatory updates

  • Coordinating screening efforts

  • Serving as the point of contact with regulatory authorities

12. Confidentiality

All sanctions-related reviews, investigations, and reports are confidential and may not be disclosed to customers or third parties except as required by law.

13. Enforcement and Disciplinary Action

Failure to comply with this policy may result in disciplinary action, up to and including termination, and may expose individuals and the business to civil or criminal penalties.

14. Policy Review and Updates

This Sanctions Compliance Policy is reviewed at least annually and updated as necessary to reflect changes in sanctions laws, regulations, or business operations.

15. Acceptance

By conducting business with The Watch Aficionado, customers and partners acknowledge and agree to comply with applicable sanctions laws and this policy.

The Watch Aficionado

Effective Date:  1/20/2026