Sanctions Compliance Policy (SCP)
Sanctions Compliance Policy
Objective
This Sanctions Compliance Policy (“Policy”) has been established by Intech Online Private Limited (“IntechDC” or “the Company”) under the Brand named IntechDC to ensure strict adherence to all applicable international sanctions and trade regulations, including but not limited to the terms of the Microsoft Services Provider License Agreement (SPLA), and relevant sanctions programs as administered and enforced by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United Nations Security Council (UNSC), the European Union (EU), and Microsoft Corporation itself. The Company recognizes the importance of maintaining a responsible compliance framework, and this Policy outlines the measures adopted to prevent any unauthorized dealings with sanctioned jurisdictions, entities, or individuals.
Scope of Application
This Policy shall apply to all employees, contractors, agents, resellers, partners, and clients of Intech Online Private Limited under the Brand IntechDC, as well as all end-users who engage with the Company’s infrastructure and services under the “IntechDC” brand. The scope extends to all cloud, infrastructure, and software offerings that rely on Microsoft SPLA-licensed technology or infrastructure. The obligations contained herein are binding across all tiers of service engagement and are integral to the contractual relationship between IntechDC and its clients or business associates.
Compliance Requirements
In compliance with applicable trade laws and contractual obligations, Intech Online Private Limited under the brand IntechDC does not provide any Microsoft-licensed services—either directly or indirectly—to individuals, businesses, governments, or other entities that are located in, incorporated under, operating from, or otherwise associated with jurisdictions designated as sanctioned or embargoed. As of the effective date of this Policy, these jurisdictions include Iran, North Korea, Cuba, Syria, the Crimea region of Ukraine, the Russian Federation, and the Republic of Belarus. This list may be amended or expanded at any time in accordance with future updates from OFAC, the United Nations, the European Union, or Microsoft Corporation. IntechDC reserves the right to enforce such updates without prior notice. In addition to jurisdictional restrictions, IntechDC prohibits any dealings with persons or organizations that appear on relevant international sanctions lists. These include, without limitation, the United States Specially Designated Nationals and Blocked Persons List (SDN List), the United Nations Consolidated Sanctions List, the European Union Consolidated Financial Sanctions List, and any internal list maintained by Microsoft identifying entities prohibited from receiving its services. All clients, resellers, and associated third parties must understand that engagement with any such designated entity is a material breach of this Policy and will lead to immediate service termination and legal reporting where required.
Client Identification and Screening Procedures
As part of its client onboarding and compliance processes, IntechDC undertakes robust screening procedures to prevent the provision of services to sanctioned parties. Upon account registration and periodically thereafter, all clients are required to submit valid identification and contact information. This data is verified using third-party validation systems and cross-checked against global sanctions databases. In the event a client or associated individual is identified as a potential match on a sanctions list, IntechDC shall suspend the related account and refrain from providing services unless and until the client is cleared through appropriate due diligence.
Geolocation and Access Restrictions
IntechDC employs technological controls across its systems, including its billing platform and hosting environment, to restrict access from sanctioned territories. This includes the implementation of geolocation-based access controls to prevent users from restricted countries from accessing services, placing orders, or consuming resources provisioned under Microsoft SPLA. These controls serve as a proactive enforcement mechanism to ensure that the Company is not facilitating any unauthorized use of services from prohibited regions, even if a client seeks to bypass registration safeguards.
Client Acknowledgment and Declarations
All clients of Intech Online Private Limited are contractually required to make a formal declaration during the registration process. By proceeding with the use of services, each client certifies that they are not located in or affiliated with any sanctioned jurisdiction and that they are not subject to trade restrictions issued by the U.S. Government, the European Union, the United Nations, or Microsoft. Specifically, each client affirms the following statement: “I acknowledge and accept the Sanctions Policy and commit to not using Intech Online Private Limited’s (Brand Name: IntechDC) services in violation of any applicable sanctions.” This declaration forms a material term of the service agreement and any misrepresentation shall be treated as grounds for immediate service termination.
Employee Responsibilities and Internal Controls
Employees of Intech Online Private Limited under the brand IntechDC who are involved in client onboarding, technical support, sales, or compliance are required to remain vigilant for any behavior or activity that may constitute a violation of sanctions regulations. Technical support staff must immediately escalate any indications of attempts to bypass geographical or policy-based restrictions. Sales and account representatives are responsible for conducting Know Your Customer (KYC) due diligence, especially in enterprise-level transactions. The administrative team is tasked with maintaining logs of all compliance activities, screening alerts, and correspondence related to potential sanctions risks. These internal controls are critical for ensuring both regulatory adherence and operational transparency.
Documentation and Audit Requirements
Intech Online Private Limited maintains detailed logs and records of all compliance actions undertaken under this Policy. This includes, but is not limited to, client registration records, geolocation metadata, sanctions screening reports, access logs, and communication archives. These records are maintained by Intech Online Private Limited and may be disclosed to Microsoft or relevant regulatory authorities upon request. Retention of these records is essential to demonstrating due diligence and the Company’s ongoing commitment to regulatory compliance.
Breach of Policy and Consequences
Any actual or attempted violation of this Policy—whether by a client, employee, partner, or third-party contractor—shall be treated as a serious compliance breach. In such cases, IntechDC reserves the right to take immediate corrective actions including, but not limited to, the suspension or permanent termination of access to services, cancellation of contracts, and disclosure of the incident to competent legal or regulatory authorities. In the case of employees, willful non-compliance with this Policy may result in disciplinary action, including summary dismissal, in accordance with Company policies and applicable labor laws.
Policy Review and Amendments
This Sanctions Compliance Policy shall be reviewed no less than once every six (6) months to ensure continued alignment with applicable regulatory and contractual requirements. Reviews shall also be triggered by any material amendments to the Microsoft SPLA, new sanctions issued by OFAC, the United Nations, or the European Union, or updates to Microsoft’s compliance advisory frameworks. All modifications to this Policy shall be published and communicated internally and externally as deemed necessary.
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