Compliance with Sanctions

Last updated: Mar 17, 2025

Sanctions Systems and Controls

HORIZON OEIC LTD (“HORIZON”) acknowledges and understands that specific individuals, organisations, companies, and other entities are subject to sanctions imposed by the UNSC and the Republic of Kazakhstan.

Senior management officials of HORIZON must establish and maintain effective systems and controls to ensure that they are correctly informed and take reasonable measures to comply with relevant resolutions or sanctions issued by the UNSC, the Republic of Kazakhstan, or other sanctions applicable in the AIFC on an ongoing basis.

Senior management officials of HORIZON must comply with prohibitions on conducting transactions with designated persons and entities, following the obligations set out in the resolutions or sanctions issued by the UNSC, the Republic of Kazakhstan, or other jurisdictions as applicable in the AIFC.

Senior management officials of HORIZON must freeze the funds or other assets of designated persons and entities without delay and without prior notice pursuant to relevant resolutions or sanctions issued by the UNSC or the Republic of Kazakhstan.

The implementation of international sanctions in the AIFC is governed by the Anti-Money Laundering Rules (the “AML Rules”), which are made in recognition of the application of the Law of the Republic of Kazakhstan No 191-IV dated 28 August 2009 on counteracting legalisation (laundering) of proceeds obtained through criminal means and financing of terrorism (the “AML Law”), the Criminal Code of the Republic of Kazakhstan No 226-V dated 3 July 2014 (the “Criminal Code”) and international conventions and treaties ratified by the Republic of Kazakhstan.

Our Policies

HORIZON, a financial market participant registered and performing its activities in the AIFC, is prohibited from engaging in transactions with (or transferring value to) such sanctioned entities and individuals.

HORIZON confirms that, as of the date of signing any agreement with other parties, neither HORIZON nor its owners, shareholders, officers, board members, employees, business ventures, or any of their family members are subject to the UN sanctions and sanctions imposed by the Republic of Kazakhstan.

HORIZON further confirms that neither it nor its owners, shareholders, officers, directors, employees, business ventures, or their family members are connected to or engaged in business relationships with any sanctioned individuals, companies, organisations, or entities.

HORIZON confirms that neither it nor any of its business ventures, owners, shareholders, officers, directors, employees, or their family members are affiliated with any governmental subdivisions, agencies, instrumentalities, or government officials in a manner that would breach UN sanctions and sanctions imposed by the Republic of Kazakhstan.

No portion of investors’ payments to HORIZON will be directed to or used to benefit any sanctioned individuals, organisations, companies, or entities, as per the UN and Republic of Kazakhstan sanctions lists.

Following the foreign policy and sanctions, no portion of investors’ payments to HORIZON will be used in any manner that threatens any country’s peace, security, stability, or territorial integrity.

No portion of investors’ payments to HORIZON will be used to support, advance, or benefit actions or policies that violate or restrict any country’s human rights or fundamental freedoms.

HORIZON acknowledges that being subject to the UN sanctions and sanctions imposed by the Republic of Kazakhstan may result in the immediate suspension or termination of any agreements to ensure compliance with sanctions laws and any other termination provisions outlined in any agreements.

Responsible Department

The Financial Intelligence Unit

The Financial Intelligence Unit is responsible for coordinating the implementation of international sanctions in the Republic of Kazakhstan.

Address 010000, Astana city, Beibitshilik st., 10 Office +7 (7172) 32-13-04, 32-20-87 Helpline (duty station) +7 (7172) 70-09-51Reference email address info@afm.gov.kz