Valkyrien Holding Ltd operates in strict adherence to applicable sanctions regimes and regulatory frameworks governing defence and dual-use activities.1. Policy Statement
Valkyrien Holding Ltd (“the Company”) is committed to full compliance with all applicable economic sanctions, trade restrictions, and regulatory requirements.
The Company adopts a zero-tolerance approach to any activity that may directly or indirectly involve sanctioned individuals, entities, jurisdictions, or prohibited transactions.
2. Scope of Application
This policy applies to:
- All employees and directors
- Consultants and intermediaries
- Business partners and counterparties
- Any third party acting on behalf of the Company
3. Applicable Sanctions Frameworks
The Company considers, where relevant, sanctions regimes issued by:
- The United Kingdom (including HM Treasury / OFSI)
- The European Union
- The United States (including OFAC)
- The United Nations Security Council
- Other applicable national authorities depending on jurisdiction
Where multiple regimes apply, the Company adopts a conservative approach, applying the most restrictive measures where appropriate.
4. Prohibited Activities
The Company does not engage in activities that involve:
- Sanctioned individuals or entities
- Jurisdictions subject to comprehensive sanctions
- Transactions designed to circumvent sanctions
- Indirect dealings through intermediaries intended to obscure beneficial ownership
- Provision of goods, services, or technologies in violation of applicable restrictions
5. Counterparty Screening
Prior to entering into any engagement, the Company may conduct screening procedures including:
- Verification against sanctions lists
- Identification of ultimate beneficial ownership (UBO)
- Assessment of jurisdictional exposure
- Review of business activities and purpose
Screening may be conducted on an ongoing basis throughout the relationship.
6. Export Controls & Dual-Use Considerations
Given the nature of its activities, the Company operates with awareness of export control frameworks applicable to defence and dual-use technologies.
Where relevant:
- Transactions may be subject to licensing requirements
- Controlled technologies are handled in accordance with applicable regulations
- Engagements are structured to ensure regulatory compliance prior to execution
The Company does not undertake activities requiring authorization unless such authorization has been duly obtained.
7. Risk-Based Approach
Sanctions and regulatory compliance are integrated into the Company’s broader risk assessment framework.
Factors considered include:
- Jurisdiction of counterparties
- Nature of the technology or service
- Transaction structure
- Involvement of intermediaries
- Potential exposure to restricted sectors
Higher-risk engagements are subject to enhanced due diligence and internal review.
8. Monitoring & Controls
The Company maintains internal controls proportionate to its activities, which may include:
- Pre-engagement compliance checks
- Periodic review of counterparties
- Documentation and record keeping
- Escalation procedures for identified risks
9. Reporting & Escalation
Where concerns arise in relation to sanctions or regulatory compliance:
- Matters are escalated internally
- Engagements may be suspended or terminated
- Reporting to competent authorities may occur where required by law
10. Third-Party Compliance
The Company expects all partners and counterparties to:
- Comply with applicable sanctions and regulatory requirements
- Avoid engaging in prohibited activities
- Provide accurate and complete information when requested
Failure to meet these standards may result in termination of the relationship.
11. Legal & Regulatory Notice
Valkyrien Holding Ltd operates in sectors subject to evolving regulatory frameworks, including sanctions, export controls, and trade restrictions.
This page is provided for general informational purposes and does not constitute legal advice.
All engagements are subject to internal compliance review and formal agreement.
Closing Statement
The Company reserves the right to decline or discontinue any engagement that presents unacceptable regulatory, legal, or reputational risk.