As a legal firm incorporated in Belgium, YS Advisors is firmly committed to compliance with all applicable blocking, sectoral, financial and economic restrictive measures implemented by the United Nations, the European Union, Belgium and any other country where YS Advisors conducts its business (the sanctions).

Furthermore, any partner, lawyer or other fee earner of YS Advisors (jointly, the fee earners and each separately, a fee earner) is obliged to fulfil all applicable regulations on sanctions compliance’ introduced by bar associations to which the relevant fee earner is a member.

YS Advisors is implementing such sanctions’ policies and procedures (the SCP) as are reasonably required to comply with the sanctions’ laws and regulations. Adherence to the SCP is binding for each fee earner and employee of YS Advisors.

The SCP provides that all clients of YS Advisors (the clients) and, where applicable, their officers, directors, beneficial owners and associated parties are screened against the up-to-date versions of applicable sanctions’ lists at the time of the clients’ onboarding and at regular intervals following such onboarding. Similarly, the SCP requires sanctions’ screening of transactions and other matters for which the clients are seeking legal advice or representation.

In cases where the screening process has produced alerts, YS Advisors will carry out an enhanced due diligence and may request additional information with respect to the clients and their transactions/matters.

The SCP prohibits engaging in activities that may violate the sanctions and requires strict compliance with any applicable limitations concerning the provision of legal services and legal advice to persons from, or with respect to activities in, countries and territories that are subject to restrictive measures.

In particular, YS Advisors fully adheres to the ban of legal advisory services stipulated in Article 5(n)(2) of Regulation (EU) No. 833/2014 of 31 July 2014 and only provides such services as are not captured by the ban. To this end, YS Advisors strictly monitors direct and indirect recipients of its legal services and advice.

If clients become sanctioned, YS Advisors will freeze all funds and economic resources held by YS Advisors on behalf of such clients (if any) and will not provide any funds or economic resources, directly or indirectly, to or for the benefit of such clients, unless otherwise is allowed by applicable sanctions’ regulations or provided by conditions of a licence issued to YS Advisors by a competent national authority.

The SCP is subject to ongoing review and updates, in particular, following the imposition of new sanctions and changes of the sanctions’ laws and regulations or practice of their implementation.

This statement does not constitute any contractual obligation or create any other legal obligation that is applicable to YS Advisors. This statement provides an overview of the SCP employed by YS Advisors as of June 2024 for information purposes only.