1. Purpose and application
This Sanctions and Restricted Activity Policy explains how Briana Global Limited approaches sanctions, terrorist-property restrictions, and related restricted activity when providing its services. It applies to customers, prospective customers, people acting for a customer, beneficial owners, recipients, and transactions to the extent relevant to the services requested.
This Policy forms part of the terms and information that apply to Briana Global’s services. It should be read with Briana Global’s customer terms, privacy information, and any information or documents we request for a particular service. If there is an inconsistency, applicable law prevails. Nothing in this Policy excludes or limits any right that cannot lawfully be excluded or limited.
For this Policy, Briana Global, we, us, and our mean Briana Global Limited. A sanctions requirement means a restriction, prohibition, obligation, designation, authorisation, exemption, or other requirement that applies under the laws or contractual arrangements described in section 4. A restricted person includes a person or entity to whom a sanctions requirement applies, including through ownership, control, direction, association, or acting for another person where the relevant requirement so provides.
2. About Briana Global and our services
Briana Global Limited is incorporated in New Zealand under company number 9362687 and NZBN 9429053039798. Its registered office is 3 Garland Drive, Saint Andrews, Hamilton 3200, New Zealand.
As verified on 9 September 2026, Briana Global is registered on the New Zealand Financial Service Providers Register (FSPR) under FSP1010808 to provide changing foreign currency, issuing or managing means of payment, and operating a money or value transfer service.
Important: FSPR registration is not a licence, approval, or government endorsement of Briana Global or its services. New Zealand has no specific general licence for e-money institutions or payment service providers. Licensing or other obligations may arise under other laws depending on a provider’s business model.
Briana Global is not a broker. Briana Global does not offer contracts for difference (CFDs), derivatives, securities, investment advice, lending or credit, deposit accounts, or cryptocurrency services. This Policy does not offer financial, investment, legal, tax, or sanctions advice. Customers should obtain independent advice where appropriate.
3. Our policy commitment
We seek to comply with applicable New Zealand sanctions laws and restrictions on terrorist property. We may also apply foreign sanctions laws where they apply to Briana Global or a transaction, and lawful restrictions that are binding on us through a correspondent, payment network, scheme, payment partner, insurer, service provider, or other contractual arrangement.
We will not provide a service or process a transaction where doing so would breach an applicable legal prohibition or binding contractual restriction. We may apply additional lawful risk restrictions. The outcome for a customer or transaction depends on the facts, the applicable legal instrument, any authorisation or exemption, and relevant partner or network requirements. A hold, delay, restriction, decline, return, termination, report, or other action is not appropriate in every case and is not interchangeable with another action.
We do not publish our detailed screening settings, risk indicators, restricted corridors, case criteria, or internal decision rules. These controls may change and are maintained to support compliance, security, and the integrity of our services.
4. Sanctions and related restrictions
4.1 New Zealand sanctions implementing United Nations measures
New Zealand implements United Nations Security Council sanctions through applicable regulations made under the United Nations Act 1946. The scope and effect of each regulation may differ. When assessing a transaction, we consider the relevant current New Zealand legal instrument and its application to the persons, assets, services, goods, activities, countries, and purpose involved. A United Nations list alone is not a substitute for determining the applicable New Zealand regulation and its terms.[4]
4.2 New Zealand Russia sanctions and the MFAT register
New Zealand’s Russia sanctions are imposed under the Russia Sanctions Act 2022 and the Russia Sanctions Regulations 2022. They may concern, among other things, designated persons, assets, services, trade, transport, goods, and sectoral activity. The Ministry of Foreign Affairs and Trade (MFAT) publishes and updates the Russia Sanctions Register to help New Zealanders identify current sanctions information. The governing legal sources remain the Act, Regulations, relevant designation notices, and any applicable exemption or authorisation.
MFAT’s role in relation to the Russia sanctions regime is distinct from the functions of New Zealand Police under terrorism-suppression legislation and statutory reporting arrangements. We do not treat the MFAT register as a general Police-administered sanctions list.
4.3 Terrorism Suppression Act restrictions and New Zealand Police functions
The Terrorism Suppression Act 2002 contains restrictions relating to designated terrorist entities and their property. It can prohibit dealing with property that is owned or controlled, directly or indirectly, by a designated terrorist entity, and can prohibit making property or financial services available in the circumstances set by that Act. New Zealand Police coordinates requests to the Prime Minister for terrorist-entity designations. Police also has statutory functions relating to information and reports under the Act.[7]
Where the law requires us to take action or provide information to the Commissioner of Police or another authority, we will do so through the applicable process. This Policy does not describe our internal reporting processes or the circumstances in which information may be reported.
4.4 Foreign law and correspondent or network restrictions
Foreign sanctions laws do not automatically apply merely because a transaction involves a particular currency, country, or counterparty. Foreign law may be relevant where there is a genuine legal connection to the foreign jurisdiction. It may also be relevant where a correspondent, payment network, scheme, payment partner, insurer, service provider, or other counterparty imposes a binding contractual requirement.
Those contractual or commercial restrictions may be broader than New Zealand law. They do not replace New Zealand legal obligations. We may need to decline or restrict a service where a binding partner or network requirement applies, even if that requirement is not itself a New Zealand legal prohibition. Where appropriate, we distinguish the legal or contractual basis for our decision.
4.5 Higher-risk jurisdictions are not sanctions designations
Financial Action Task Force (FATF) publications identify jurisdictions with material anti-money laundering, countering financing of terrorism, or proliferation-financing risk concerns. FATF status is an AML/CFT risk indicator, not a sanctions designation. It does not, by itself, mean that a country, person, asset, or payment is sanctioned or that it must be frozen, declined, or reported.[8]
We may apply risk-based enhanced due diligence, obtain more information, enhance monitoring, impose limits, or apply other lawful restrictions to a transaction or relationship with a higher-risk jurisdiction or sanctions-evasion risk. Any such measure depends on our risk assessment, applicable law, and partner requirements.
4.6 Politically exposed persons are treated separately
A politically exposed person (PEP) is not, solely because of that status, a sanctioned person. We take reasonable, risk-based steps to determine whether a customer or beneficial owner is a PEP. Where required by AML/CFT law, we obtain appropriate senior-management approval to continue a business relationship and obtain and verify information about source of wealth or source of funds. We may also apply enhanced due diligence and monitoring that are appropriate to the risk.
We may screen other people connected with a transaction as part of our risk controls. PEP treatment is separate from sanctions screening. A PEP finding alone is not a basis to treat a person, asset, or transaction as sanctioned.
5. Ownership, control, and connected persons
A restricted person may not be named directly in a public register or list. Depending on the applicable legal, contractual, or partner requirement, restrictions may also apply where a person or entity is owned, controlled, directed by, acting for, or otherwise connected with a restricted person.
When this is relevant, we may consider direct and indirect ownership, beneficial interests, voting rights, governance or appointment rights, powers of direction, representatives, intermediaries, associates, and whether a person is acting on another’s behalf. The ownership and control test may differ between legal regimes and contractual requirements. We apply the relevant current test rather than a single published percentage or automatic rule.
We may ask for documents or information about the ownership, control, management, purpose, source of funds, source of wealth, end use, goods or services, routes, intermediaries, and beneficiaries of a relationship or transaction. We may restrict the relationship or transaction while that information is considered.
6. Restricted and prohibited activity
You must not use, attempt to use, or allow another person to use Briana Global’s services in a way that would breach a sanctions requirement or otherwise facilitate prohibited activity. This includes activity that involves or may involve:
a restricted person or restricted property;
a prohibited asset, service, good, trade, sector, activity, country connection, route, destination, end user, or end use;
a transaction that directly or indirectly benefits a restricted person where the applicable requirement prohibits that benefit;
an attempt to evade, avoid, circumvent, conceal, or defeat a sanctions requirement or a lawful partner or network restriction;
false, misleading, incomplete, or altered information or documents, including information about identity, ownership, control, payment purpose, goods, services, origin, destination, or end use; or
a business relationship or activity that is prohibited by applicable AML/CFT law, including a relationship involving a shell bank where the law prohibits it.
A country connection alone does not necessarily mean that a transaction is prohibited. Equally, the absence of a named-person match does not establish that a transaction is permitted. The purpose of the payment and the surrounding facts can be relevant to a sanctions assessment.
7. Screening and review
We may screen customers, beneficial owners, directors, authorised representatives, signatories, recipients, senders, other relevant payment parties, and transactions. Screening may occur when a customer applies for a service, during a relationship on a risk-based basis, when information changes, and when we assess a transaction. The checks performed depend on the information available, the service, the transaction, and the screening controls that apply.
A potential match does not necessarily mean that a person or transaction is restricted. We may review appropriate identifiers and other information, including identity, ownership, control, transaction purpose, goods or services, and relevant country or route information. We may request additional information or documents.
While we make enquiries or meet applicable legal, contractual, or partner requirements, we may delay, restrict, decline, return, or cancel a transaction, decline or restrict an application, or suspend or end a service where permitted. We will not process a transaction that would breach applicable law or a binding contractual restriction.
8. Customer duties and changes
You must provide information and documents that are accurate, complete, current, and not misleading. You must promptly tell us about a material change that may affect our assessment of you, a beneficial owner, a representative, a recipient, a transaction, or a related activity. Examples include a change in ownership or control, a new authorised representative, a change in a transaction’s purpose, goods or services, end user, route, destination, or country connection.
You must respond reasonably to our requests for information or documents. Your confirmations and information do not limit our right or obligation to carry out our own checks, request further information, delay, restrict, decline, terminate, or take other action as permitted or required.
9. Communications, privacy, and disclosures
Where lawful and appropriate, we may tell you that we cannot process a transaction, that a service is restricted, or that we need further information. We may not be able to provide detailed reasons, confirm whether a report has been made, or disclose information about a review, investigation, law-enforcement communication, partner instruction, or other restricted matter. This may be because of law, confidentiality obligations, the need to protect an investigation, or the requirements of a payment partner or network.
We may collect, use, verify, and disclose personal information and transaction information as permitted or required by law and as described in our privacy information, including for identity verification, AML/CFT, sanctions, fraud prevention, transaction processing, and compliance purposes. For privacy questions or requests, contact support@brianaglobal.com.
10. Error correction, review, and complaints
If you believe that information we hold is incorrect, that you have been incorrectly identified, or that a sanctions or restricted-activity decision should be reviewed, contact compliance@brianaglobal.com. Please provide enough information and supporting documents for us to assess the issue. We will consider relevant information to the extent permitted by law and our obligations. A request for review does not require us to process or release a transaction while a legal, contractual, partner, or risk review remains unresolved.
For help with a service, contact support@brianaglobal.com To make a complaint, contact complaints@brianaglobal.com. We will handle complaints under our complaints process and in accordance with applicable requirements.
Briana Global’s FSPR record lists membership of Financial Services Complaints Limited (FSCL) – a Financial Ombudsman Service, membership number 9518, effective 13 November 2025. If you are not satisfied with our response, you may be able to refer an eligible complaint to FSCL. FSCL’s current contact details include 0800 347 257, +64 4 472 3725 from overseas, complaints@fscl.org.nz, and PO Box 5967, Wellington 6140. FSCL’s process and eligibility requirements apply.[9]
11. Changes to this Policy
We may amend this Policy to reflect changes in law, regulatory guidance, sanctions requirements, services, risk, or partner and network requirements. The current version will be published on our website with its effective date. A change does not affect rights that cannot lawfully be changed.
12. Contact details
Briana Global Limited
Company number: 9362687
NZBN: 9429053039798
FSPR registration: FSP1010808
Registered office: 3 Garland Drive, Saint Andrews, Hamilton 3200, New Zealand
Support: support@brianaglobal.com
Complaints: complaints@brianaglobal.com
Privacy: support@brianaglobal.com
Compliance and sanctions review: compliance@brianaglobal.com
Version 1.0 | Effective 9 September 2026