Effective Date: August 2025

This policy defines the approach of Totsi Island Properties Group I.K.E., operating as Havenbach, toward compliance with international sanctions, embargoes, and restricted party regulations. It applies to all services offered through havenbach.com and affiliated operations.

1. Policy Statement

Havenbach is committed to full compliance with applicable international sanctions regimes, including those imposed by:

• The European Union (EU)

• The United Nations (UN)

• The United States Office of Foreign Assets Control (OFAC)

• The UK Sanctions List and other relevant national authorities

We do not knowingly engage with any individual, organization, or jurisdiction under sanctions or subject to trade restrictions.

2. Prohibited Engagements

We do not provide services to or on behalf of:

• Individuals or entities listed on any international sanctions or watchlist

• Persons ordinarily resident in embargoed jurisdictions who are individually sanctioned or politically exposed

• Governments, agencies, or state actors subject to full international trade/mobility restrictions

• Individuals acting as proxies or intermediaries for sanctioned persons

3. Jurisdictional Review

Havenbach does not apply blanket exclusions by nationality. Instead, we apply enhanced due diligence and case-by-case screening for clients from:

• Russia (including Crimea, Donetsk, Luhansk regions)

• Belarus

• Syria

• Iran

• North Korea (fully restricted)

• Cuba (case-by-case, with screening)

Clients from these countries may still access our services if:

• They are not listed on international watchlists

• They pass our internal KYC and sanctions screening

• Their use case is legally compliant and serviceable under EU/Greek law

4. Screening & Monitoring

We perform identity and compliance checks on all clients using tools that include:

• Document and identity verification

• Sanctions and PEP list screening

• Risk-based analysis based on nationality, funding source, and destination

Clients must cooperate with any request for identification, source of funds documentation, or other screening procedures.

5. Consequences of Breach

If a client is found to be in violation of this policy, Havenbach reserves the right to:

• Immediately terminate all services and engagements

• Report the activity to relevant regulatory or enforcement bodies

• Withhold any documentation, applications, or refunds

No liability is accepted for losses arising from termination due to sanctions exposure.

6. Updates & Amendments

This policy is reviewed regularly and updated in line with international sanctions developments. Clients are encouraged to check this page periodically.

7. Contact

For sanctions-related inquiries: 📧 Email: [email protected]
📞 Phone (GR): +30 698 3200 953
📞 Phone (AL): +355 68 60 80 345

By using Havenbach services, you confirm that you are not subject to any applicable sanctions or restrictions and that you understand and accept the terms of this policy.