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L03 Legal · Sanctions & KYC

Sanctions
& KYC.

Operating in the Syrian context demands the strictest sanctions and KYC posture. The corridor's onboarding regime is built around full UBO disclosure, multi-regime screening, and continuous monitoring — applied identically to anchors, vendors, and individuals.

STATUSMandatory · All counterparties
SCREENING REGIMESOFAC · UK OFSI · EU consolidated
VERSIONv1.2 · 2026-05-13
REVIEWED BYExternal counsel · quarterly
On this page
  1. Posture
  2. Regimes screened
  3. Scope of screening
  4. UBO methodology
  5. Onboarding pathway
  6. Vendor onboarding
  7. Refusal & appeal
  8. Ongoing monitoring
  9. Contact

01 · The KETURAH posture

The KETURAH Master Entity applies a strictest-of-all-regimes posture: a counterparty is cleared only if it passes screening against every applicable sanctions list — not the lightest one. The same screening is applied to every category of counterparty: sovereign anchors, DFIs, institutional investors, foundations, vendors, advisers, and individuals named in the title chain.

Sanctions failure = onboarding hard stop. A hit on any screened regime is treated as a critical-tier risk (Risk Register R-01, Verification Gate VG-PLAT-05). The decision is binary; there is no scope for commercial override.

02 · Regimes screened

Screening is conducted against the live consolidated lists of the following authorities (non-exhaustive; supplemented by additional regimes where the counterparty's jurisdiction requires it):

OFAC · US

Office of Foreign Assets Control — Specially Designated Nationals (SDN), Sectoral Sanctions Identifications (SSI), Non-SDN Menu-Based Sanctions, Caesar Act–related designations.

OFSI · UK

Office of Financial Sanctions Implementation — UK consolidated list under the Sanctions and Anti-Money Laundering Act 2018.

EU

EU consolidated sanctions list, including Council Regulation (EU) No 36/2012 restrictive measures concerning the situation in Syria, with updates as published.

Additional checks: UN Security Council consolidated list; Politically Exposed Persons (PEP) registers; adverse media (recognised compliance databases); and counterparty-jurisdiction–specific lists where applicable.

03 · Scope of screening

For each counterparty, screening covers:

  • The legal entity itself, including all known trading names and historic names;
  • Every director, officer, and authorised signatory;
  • Every shareholder above 10% — direct, indirect, and through nominee structures;
  • Every ultimate beneficial owner (UBO) at any level of the corporate chain (see UBO methodology below);
  • Counterparty group affiliates where the relationship is sufficient to create sanctions exposure under the 50% rule;
  • For vendors: subcontractors and material supply-chain participants down to the second tier where the contract permits.

04 · UBO methodology

The corridor's ultimate-beneficial-owner methodology is built on the FATF UBO definition, hardened for the Syrian context:

  • Look-through threshold: 10%. Any natural person holding 10% or more directly or through chains is identified.
  • Multi-jurisdiction chains. Where the chain crosses jurisdictions with thin disclosure (offshore vehicles, trusts), the counterparty must provide either certified corporate registry extracts or a statutory declaration from a regulated professional.
  • Trust + foundation transparency. Settlors, protectors, named and class beneficiaries are all in scope.
  • Nominee structures rejected. Where the chain reveals nominee shareholding without an identifiable beneficial principal, onboarding is paused until cleared.
  • The 50% rule. An entity 50%-or-more owned (directly or indirectly) by a sanctioned person is itself treated as sanctioned, even if not named on a list.

05 · Onboarding pathway

01

Counterparty submits initial form

Entity name, jurisdiction, contact, intended scope of engagement, and named principals. Submitted via the Request Diligence form.

02

KYC pack request

KETURAH responds with a KYC pack listing the documentation required: corporate registry extract; constitutional documents; UBO chain to natural persons; passports of principals; proofs of address; source-of-funds narrative.

03

Multi-regime screening

Compliance team runs the entity, principals, and UBOs against OFAC, OFSI, EU, UN, PEP, and adverse-media databases. Documented in a screening file with timestamp and watermark.

04

Internal credit + integrity review

Where screening returns no hit, the file proceeds to internal review for credit quality and integrity factors not surfaced by automated screening (jurisdictional residence, source-of-wealth coherence, sectoral exposure).

05

Clearance & NDA execution

Cleared counterparties receive notice and execute the mutual NDA. Data-room credentials follow within five business days. Refusal is communicated in writing with a redacted basis where lawful.

06 · Vendor onboarding

Vendors face the same screening, with two additions:

  • Supply-chain trace. For material categories (construction systems, IT, security equipment), the immediate vendor must trace material flow at least one tier upstream and provide that mapping to KETURAH compliance.
  • Sectoral overlays. Goods or services subject to the EU dual-use regulation, the US ITAR/EAR regime, or UK strategic goods control require sectoral clearance in addition to entity screening.

Vendor non-compliance is tracked in the Risk Register as R-10 (critical tier).

07 · Refusal & appeal

A counterparty who is refused onboarding may request a re-review where they believe the screening result is the consequence of a false positive (homonym, outdated record, jurisdictional ambiguity). Re-review is performed by a second compliance officer; where the result holds, the decision is final at this stage. A counterparty can re-apply at any time if the underlying circumstances change.

08 · Ongoing monitoring

Cleared counterparties are re-screened:

  • Quarterly for active framework-agreement holders;
  • Annually for institutional NDA holders without active commitment;
  • Immediately upon any material change in the counterparty's stated UBO chain, jurisdiction, or principal officers;
  • Immediately upon any change to the underlying sanctions regimes that could affect their status.

09 · Contact

Sanctions and KYC enquiries are directed via the Request Diligence form with the subject line SANCTIONS/KYC. All correspondence is logged in the compliance file.

This policy is non-negotiable. No anchor, sponsor, or strategic ask overrides the screening result. The discipline is institutional; the corridor's integrity depends on it.

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