Effective date: 1 May 2026 · Last updated: 12 May 2026 · Owner: Money Laundering Reporting Officer (MLRO) · Review cycle: Annual; sanctions-list reviews quarterly
1. Purpose
ERAM Real Estate Sh.P.K. complies with all economic and trade sanctions applicable to its activities, including those administered by the United Nations Security Council, the European Union, the Office of Foreign Assets Control of the United States Treasury (OFAC), HM Treasury (United Kingdom), and any sanctions adopted or recognised by the Republic of Kosovo.
This policy sets out the principles, screening commitments and escalation procedures by which ERAM avoids any direct or indirect dealings with sanctioned persons, entities, vessels or jurisdictions.
2. Scope
This policy applies to every customer, investor, supplier, contractor, service provider, beneficial owner, and counterparty of ERAM and its project SPVs. It applies regardless of the location, nationality or domicile of the counterparty.
3. Sanctions lists screened
ERAM screens, at onboarding and on a continuous basis, against the following consolidated lists at a minimum:
- United Nations Security Council Consolidated List;
- European Union Consolidated List of persons, groups and entities subject to financial sanctions;
- OFAC Specially Designated Nationals (SDN) List and Sectoral Sanctions Identifications List;
- HM Treasury (UK) Consolidated List of financial sanctions targets;
- Politically Exposed Persons (PEPs) databases for enhanced-due-diligence triggers;
- Any list adopted or recognised by the Government of the Republic of Kosovo.
4. Restricted jurisdictions
ERAM does not knowingly establish business relationships with persons or entities resident in, operating from, or with material economic ties to comprehensively-sanctioned jurisdictions as designated by the EU, UN, OFAC, or HM Treasury. The list of restricted jurisdictions is maintained internally by the MLRO and updated as sanctions regimes evolve.
5. Screening procedures
Sanctions screening is automated and performed by ERAM's KYC service provider at the point of onboarding for every investor, and at the contract-execution stage for every unit-buyer above the AML threshold. Screening is repeated on a continuous basis as lists are updated.
True or possible matches trigger immediate review by the MLRO. Onboarding is suspended pending resolution. Confirmed matches result in refusal of the relationship and, where required by law, reporting to the FIU-K.
6. Existing customers and ongoing monitoring
Existing customers are re-screened automatically when sanctions lists are updated. A confirmed positive match against an existing customer triggers immediate freezing of any pending transaction, escalation to the MLRO, legal review, and reporting to competent authorities as required.
7. Prohibited conduct
Directors, officers, employees, contractors and agents of ERAM are prohibited from:
- Knowingly engaging in any transaction with a sanctioned person, entity, vessel or jurisdiction;
- Structuring, restructuring or routing transactions to evade or circumvent applicable sanctions;
- Providing, directly or indirectly, any economic resource to a sanctioned target;
- Failing to escalate a positive or possible sanctions screening match to the MLRO.
Breach of this prohibition is a serious disciplinary matter and may constitute a criminal offence.
8. Governance
Responsibility for sanctions compliance is held by the MLRO, who reports to the board. The list of screening lists and restricted jurisdictions is reviewed at least quarterly. This policy is reviewed at least annually.
Contact
Questions regarding this policy, or to report a concern: [email protected]. Confidential reports may also be made via our Whistleblowing channel.
ERAM Real Estate Sh.P.K. · Business no. (NUI) 812052025 · Registered 13/06/2023 · Rruga Agim Ramadani, Nr. 2, 10000 Prishtina, Kosovo