Sanctions and Compliance Policy
This policy explains how Quantum Intelligence Hub Ltd (“QIH”) manages sanctions, export-control, financial-crime and bribery risks in connection with its digital infrastructure, AI Digital Reception, automation, cybersecurity, education, e-commerce, international trade support and related services.
As a company subject to United Kingdom law, QIH complies with applicable UK sanctions. United Nations, European Union, United States and relevant local sanctions may also be considered where required by the parties, currency, service provider or country connected with a transaction.
1. Purpose and Scope
This policy applies to QIH, its employees, authorised representatives and contractors, and to customers and business partners using QIH services. Its purposes are to:
- prevent dealings with prohibited persons, entities, vessels or structures;
- reduce the risks of sanctions evasion, money laundering, terrorist financing and fraud;
- observe export-control and dual-use rules;
- prevent bribery, corruption and improper payments;
- maintain a reasonable, documented and risk-based compliance process.
2. Applicable Sanctions Frameworks
QIH primarily relies on the UK Sanctions List and applicable UK legislation. Depending on the transaction’s connections, the following may also be reviewed:
- UK FCDO, OFSI and OTSI rules and guidance;
- United Nations Security Council sanctions;
- European Union restrictive measures;
- US OFAC sanctions, particularly where a US person, bank, platform or US-dollar transaction is involved;
- mandatory sanctions and export-control rules in the country of activity or residence of the customer.
Since 28 January 2026, the UK Sanctions List has been the single official source for all UK sanctions designations. The former OFSI Consolidated List is no longer used.
3. Country and Regional Risk
Sanctions do not necessarily create a blanket prohibition against every citizen or every type of trade involving a country. Restrictions may apply to specified persons, entities, sectors, goods, services, technologies, territories or transaction types.
QIH assesses current official lists and the relevant transaction links. A high-risk or legally uncertain transaction may be rejected, paused or referred for specialist legal review.
4. Customer and Business-Partner Checks
Where justified by the nature and risk of a service, QIH may carry out:
- identity, company-registration, address, director and beneficial-owner verification;
- screening against the UK Sanctions List and other relevant lists;
- politically exposed person (PEP) and adverse-media checks;
- requests for information about source of funds, source of wealth, payment purpose and end use;
- reassessment when a relationship changes or a new risk indicator arises.
Where reasonably possible, QIH verifies identity and context rather than making a conclusive decision solely from an automated name match.
5. Financial Crime and Suspicious Activity
QIH complies with financial-crime laws applicable to its activities. If a QIH service falls within a regulated sector, the relevant AML supervision and obligations under the Money Laundering Regulations 2017 will apply separately.
QIH may refuse unexplained payments, false or misleading documents, concealed beneficial ownership, unusual payment routes or transactions suspected of facilitating sanctions evasion. Where a legal reporting obligation arises, the matter may be referred to the competent authority.
6. Export Controls and Dual-Use Items
Cybersecurity tools, encryption, artificial intelligence, software, technical data, training materials and other goods or services may be subject to export controls. Where appropriate, QIH may:
- assess the product, software, technology, destination, user and intended end use;
- pause supply until a licence or authoritative opinion is obtained;
- review re-export and third-country transfer risks;
- reject requests involving suspected military, weapons, repression, surveillance or unlawful cyber use.
7. Anti-Bribery and Corruption
QIH has no tolerance for bribery, facilitation payments, secret commissions or improper benefits and applies the principles of the UK Bribery Act 2010.
- No advantage may be offered to a public official or private person to obtain business or an improper benefit.
- Gifts, hospitality, travel and sponsorship must be reasonable, transparent and legitimate.
- Improper payments may not be routed through agents, advisers, resellers or business partners.
- Suspicious requests must be reported promptly to QIH Compliance.
8. Records and Data Protection
Personal data processed for compliance checks is used for specified and legitimate purposes in accordance with UK GDPR and the Data Protection Act 2018. Records are kept only for as long as necessary, taking account of legal obligations and limitation periods.
Information may be disclosed where required by law, sanctions compliance, fraud prevention, protection of legal rights or a lawful request from a competent authority. Access is limited according to role and need.
9. Measures Following a Risk or Breach
Where QIH reasonably identifies a sanctions or compliance risk, it may:
- request additional information and documents;
- temporarily pause payment, access, delivery or service;
- reject a transaction or terminate the contractual relationship;
- delay a refund until legal or banking restrictions are resolved;
- report the matter to a competent authority where legally required.
QIH may be prohibited by law from disclosing details of an investigation or report to the customer.
10. Customer Representations and Duties
Each customer and business partner represents that:
- its identity, ownership, activity and payment information is accurate;
- it is not acting for or for the benefit of a sanctioned person;
- it will not use QIH services for sanctions evasion, financial crime or unlawful purposes;
- it will not conceal the end user, payment party or purpose of the service;
- it will promptly notify QIH of changes affecting its risk status.
A false representation may result in suspension or termination and recovery from the responsible party of losses caused by that misrepresentation.
11. Allocation of Responsibility
Each party is responsible to the extent of its own acts, omissions, misrepresentations and breach of legal duty. The customer remains responsible for the legality of its products, transactions, end use, recipients and local operations.
QIH’s good-faith and reasonable compliance review does not remove the customer’s independent legal obligations. Nothing in this policy excludes QIH’s liability for its own wilful or negligent breach where that liability cannot lawfully be limited.
12. Reports, Complaints and Updates
A suspected sanctions, bribery, export-control or financial-crime matter may be reported to compliance@qihhub.com. Good-faith reports are assessed confidentially and under a non-retaliation principle.
QIH may update this policy in response to changes in law, official lists, risk or services. Material changes apply from publication. Subject to mandatory local law, this policy is governed by the laws of England and Wales.
13. Contact and Official Sources
QUANTUM INTELLIGENCE HUB LTD
71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Compliance: compliance@qihhub.com
Legal: legal@qihhub.com
Security: security@qihhub.com
Official sources: UK Sanctions List · UK Sanctions Guidance · Current UK Sanctions Regimes