OFAC Statement

OFAC/Sanctions Policy

Last updated: 11/09/2024

Purpose

The purpose of this Policy is to ensure that SpeakMyDesires.com operates in full compliance with the economic and trade sanctions set forth by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). These sanctions support foreign policy and national security objectives and may apply to specific foreign countries and regimes, as well as to individuals and entities that pose risks related to terrorism, international narcotics trafficking, proliferation of weapons of mass destruction, or other activities that threaten national security or the economic well-being of the United States and other jurisdictions where SpeakMyDesires.com conducts business.

Policy Statement

SpeakMyDesires.com adheres to all OFAC regulations and relevant sanctions programs, working diligently to align our operations with U.S. laws and any additional regulatory requirements within the jurisdictions where we operate. Beyond OFAC’s oversight, the U.S. Department of Commerce and Department of State impose additional export control requirements on certain goods and technology, including but not limited to encryption tools, restricted software, and certain electronic equipment. These regulations may necessitate licensing or impose export restrictions based on factors such as the product category, intended end-use, or specific end-user restrictions.

In compliance with these regulations, SpeakMyDesires.com enforces strict policies to ensure that our operations, customers, vendors, and other business associates are screened and monitored to avoid any prohibited activities with Sanctions Targets, defined as individuals or entities designated under OFAC or other applicable sanctions lists.

Key Compliance Procedures

  1. Screening Protocols: SpeakMyDesires.com has implemented a robust screening system to check all potential and existing customers, vendors, payees, and business associates against OFAC’s Specially Designated Nationals (SDN) list, as well as against other applicable sanction lists published by jurisdictions in which we operate. This includes periodic rescreening to account for any updates to these lists, ensuring continuous compliance.
  2. Identification of Sanctions Targets: OFAC, along with other regulatory authorities, regularly publishes and updates lists of Sanctions Targets. These lists include:
    • Individuals and organizations associated with sanctioned countries and regions.
    • Persons or entities involved in illegal activities, such as terrorism, narcotics trafficking, or arms proliferation.
    • Specific entities identified as threats to national security, foreign policy, or economic stability.

    SpeakMyDesires.com applies these lists during onboarding and throughout our engagement with customers and business partners, immediately flagging any individuals or entities that match the descriptions on these lists.

  3. Export Control Compliance: For any transactions involving export-controlled goods, software, or technology, SpeakMyDesires.com ensures that we obtain the necessary export licenses, where applicable. We assess the nature of the product, the final destination, and the end-user before proceeding with any potentially restricted transactions. Should we encounter prohibited exports, we take steps to halt the transaction and prevent further actions that may conflict with U.S. and international export control laws.
  4. Jurisdictional Sanctions Compliance: In addition to OFAC guidelines, other countries where SpeakMyDesires.com conducts business may enforce their own sanctions programs. We maintain updated procedures to incorporate these additional restrictions into our compliance framework, ensuring our adherence not only to U.S. sanctions but also to other relevant regulatory requirements.
  5. Employee Training and Awareness: SpeakMyDesires.com provides mandatory training for all employees on OFAC compliance and sanctions policies. This training covers the importance of compliance with sanctions laws, the procedures in place for identifying and avoiding Sanctions Targets, and the consequences of non-compliance for both the company and individual employees. We continuously update our training programs to reflect any changes in OFAC policies or other relevant sanctions regimes.
  6. Internal Monitoring and Auditing: To verify our ongoing compliance, SpeakMyDesires.com performs regular audits of our transactions, screening processes, and export control procedures. These audits are designed to detect any potential compliance issues and to refine our procedures to prevent future occurrences. Any instances of non-compliance are addressed immediately, with corrective actions implemented to mitigate risks.
  7. Reporting and Accountability: In the event of a potential match with a Sanctions Target, SpeakMyDesires.com has established protocols for reporting the activity to the relevant authorities. We maintain detailed records of our compliance activities, screening results, and any remedial actions taken in response to detected issues.

Conclusion

SpeakMyDesires.com is committed to upholding the highest standards of compliance with OFAC and other international sanctions requirements. Our goal is to maintain a secure, responsible platform for all adult services while fully adhering to U.S. and global sanctions laws. By implementing stringent compliance measures, conducting thorough screening, and engaging in continuous training and monitoring, we strive to operate responsibly within all applicable legal frameworks.