We the board drafted the Midland Cosmos ltd 's international sanctions policy
As of 2026, Midland Cosmos Ltd operates as an international trade and investment entity. Given the global nature of its operations, its International Sanctions Policy is designed to ensure strict compliance with restrictive measures imposed by major jurisdictions.
Below is a draft policy based on current 2026 global compliance standards for multi-jurisdictional trading companies.
International Sanctions Policy: Midland Cosmos Ltd
Effective Date: January 1, 2026
Version: 2026.1
1. Statement of Intent
Midland Cosmos Ltd is committed to the highest standards of integrity and legal compliance. We maintain a zero-tolerance approach toward violations of international economic sanctions and trade embargoes. This policy ensures that our operations do not inadvertently support prohibited regimes, terrorists, or sanctioned individuals.
2. Scope and Applicability
This policy applies to all Midland Cosmos Ltd employees, directors, subsidiaries, and third-party intermediaries (including agents and joint venture partners) regardless of their geographic location.
3. Compliance Framework
Midland Cosmos Ltd adheres to the sanctions regimes of the following primary jurisdictions, in addition to local laws where we operate:
United Nations (UN): Security Council Consolidated Sanctions.
United States: Office of Foreign Assets Control (OFAC) regulations.
European Union (EU): Consolidated list of persons, groups, and entities subject to EU financial sanctions.
United Kingdom: Office of Financial Sanctions Implementation (OFSI) regimes.
4. Prohibited Activities
Unless authorized by a specific license from the relevant governing authority, Midland Cosmos Ltd prohibits:
Direct or Indirect Trade: Engaging in business with any person or entity listed on a "Restricted" or "Denied" party list.
Sanctioned Jurisdictions: Facilitating transactions involving high-risk regions currently under comprehensive embargo (e.g., North Korea, Iran, Cuba, and occupied regions of Ukraine).
Dual-Use Goods: Exporting items with potential military applications to restricted end-users.
5. Know Your Counterparty (KYC) & Screening
Midland Cosmos Ltd mandates rigorous "Level 1" and "Level 2" screening for all new business relationships:
Automated Screening: All partners are screened against the Global Sanctions List before any contract execution.
Ultimate Beneficial Ownership (UBO): We perform "50% Rule" checks to ensure no sanctioned individual holds a majority or controlling interest in a counterparty.
6. Reporting and Escalation
Suspicious Activity: Any employee who identifies a potential sanctions match or "red flag" (e.g., unusual payment routing or vague shipping destinations) must immediately report it to the Chief Compliance Officer.
Transaction Blocking: If a sanctions hit is confirmed, the transaction must be frozen immediately. Midland Cosmos Ltd will not proceed with any business that risks violating international law.
7. Training and Audits
Annual Training: All staff must complete mandatory sanctions compliance training by Q1 of each year.
Periodic Audits: Our compliance department conducts bi-annual audits of all trade documentation to ensure screening protocols were followed.
8. Consequences of Non-Compliance
Violations of this policy may lead to severe legal penalties for the company and disciplinary action for employees, up to and including termination and referral to law enforcement.
Disclaimer: This document is a draft for informational purposes and should be reviewed by legal counsel to ensure it meets the specific regulatory requirements of your local jurisdiction and the exact nature of Midland Cosmos Ltd's 2026 operations
To finalize the Midland Cosmos Ltd International Sanctions Policy for 2026, the following sections address the operational implementation, "red flag" identification, and the specific clause requirements for modern trade contracts.
9. Identification of "Red Flags"
Employees must exercise enhanced due diligence if any of the following "Red Flags" are identified during the course of business:
Vague Documentation: A counterparty is reluctant to provide information regarding the end-use or end-user of a product.
Third-Party Payments: Requests to make or receive payments from a country not involved in the transaction or from an unrelated third party.
Abnormal Routing: Shipping routes that involve stops in sanctioned jurisdictions without a clear commercial justification.
Shell Companies: The use of entities that have no physical presence or appear to have been created solely to obscure ownership.
10. Standard Sanctions Clauses
Midland Cosmos Ltd shall incorporate a "Sanctions Compliance Clause" into all international sales, purchase, and service agreements. This clause must stipulate:
The counterparty warrants that they are not a "Sanctioned Person" or owned/controlled by one.
Midland Cosmos Ltd reserves the right to terminate the contract immediately and without penalty if a counterparty becomes sanctioned or violates trade laws.
The counterparty agrees to indemnify Midland Cosmos Ltd against any losses resulting from their breach of international sanctions.
11. Circumvention and Facilitation
Midland Cosmos Ltd strictly prohibits "facilitation"—the act of assisting a non-U.S. or non-EU person in a transaction that would be prohibited if performed by a Midland Cosmos entity. This includes:
Altering invoices or shipping documents to hide the origin of goods.
Suggesting alternative banking routes to bypass sanctions filters.
Using personal accounts to settle corporate obligations related to high-risk territories.
12. Record Keeping
In alignment with 2026 international auditing standards, all screening results, due diligence reports, and correspondence related to sanctions queries must be archived for a minimum of seven (7) years. These records must be readily accessible for inspection by the U.K. OFSI or other relevant authorities.
13. Policy Review Cycle
The global sanctions landscape is volatile. This policy will be reviewed by the Board of Directors and the Legal Department on a bi-annual basis (every six months) or immediately following a significant change in international law (e.g., new UN resolutions or emergency executive orders).
14. Contact Information
For questions regarding this policy or to report a potential breach, please contact:
Compliance Department: compliance@midlandcosmos.com
Internal Whistleblower Hotline: [Insert Secure Link/Phone Number]
Approval and Adoption
This policy was formally adopted by the Board of Midland Cosmos Ltd on January 1, 2026.
Signed,
Chief Executive Officer
Midland Cosmos Ltd
Actionable Resources for 2026 Compliance:
Daily Screening: Use the Consolidated Sanctions List (Search Tool) to check individual names or entities.
EU Updates: Monitor the European Commission Sanctions Map for real-time changes to European restrictions.
Advisory: Consult the ICC (International Chamber of Commerce) guidelines for best practices in 2026 trade finance compliance
To further align Midland Cosmos Ltd with the high-compliance expectations of 2026, the following supplemental sections address modern enforcement trends, including maritime security, AI-driven risks, and specific regulatory shifts in the UK and EU.
Given the heightened focus on "Shadow Fleets" and maritime circumvention in 2026, Midland Cosmos Ltd implements the following:
Vessel Screening: All vessels involved in transporting goods for Midland Cosmos Ltd must be screened against the latest OFAC and EU maritime sanctions lists.
AIS Monitoring: We reserve the right to verify that a vessel's Automatic Identification System (AIS) has not been manipulated or disabled during its voyage to hide its location.
Shadow Fleet Due Diligence: We prohibit the use of vessels that lack clear beneficial ownership or are operated by entities with a history of sanctions-evasion activities.
16. AI and Technology Controls
As of 2026, regulators expect companies to address risks associated with the misuse of Artificial Intelligence:
Synthetic Identity Detection: Our screening software is configured to detect patterns associated with AI-generated "synthetic identities" designed to bypass traditional name-matching filters.
Dual-Use AI Software: Any software or technology transfer related to AI model weights or advanced computing must be screened against the latest export controls.
17. Expanded "50% Rule" and Beneficial Ownership
In accordance with 2026 standards, Midland Cosmos Ltd applies a strict interpretation of ownership:
Aggregate Ownership: An entity is considered sanctioned if it is owned 50% or more in the aggregate by one or more sanctioned persons.
Control vs. Ownership: Even if ownership is below 50%, a relationship may be prohibited if a sanctioned person exercises "control" over the entity's board or operational decisions.
18. UK and EU Specific Enforcement (2026)
UK OTSI Compliance: Midland Cosmos Ltd strictly adheres to the mandates of the Office of Trade Sanctions Implementation (OTSI), which now has full operational power to target trade sanctions circumvention and mischaracterized services.
EU Russia Extension: In light of the EU's extension of Russia-related economic measures until at least July 31, 2026, all trade in energy, technology, and dual-use goods remains under maximum-security review.
19. Forced Labor and ESG Integration
To further develop the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections focus on emerging technology risks, cross-border investment due diligence, and specialized "Secondary Sanctions" compliance.
20. Technology-Driven Evasion and AI Protections
In response to 2026 enforcement trends, Midland Cosmos Ltd acknowledges that sanctioned actors may use advanced technology to disguise their identities.
Synthetic Identity Screening: Our compliance software is equipped to flag potential "synthetic identities"—AI-generated persona data used to create shell companies that bypass traditional name-matching filters.
AI Explainability: When AI-driven tools are used for transaction monitoring, Midland Cosmos Ltd maintains a "human-in-the-loop" requirement to ensure all automated decisions can be audited and explained to regulators.
21. Investment and Venture Capital Due Diligence
As a 2026 international investment entity, Midland Cosmos Ltd applies rigorous standards to its capital deployments:
Sub-50% Thresholds: We evaluate "Economic Interest" beyond formal ownership. If a sanctioned person holds significant economic leverage or "practical control" over a target company, the investment is prohibited regardless of the specific ownership percentage.
Portfolio Audits: Existing portfolio companies must undergo annual sanctions health checks to ensure their own supply chains and customer bases remain compliant with 2026 global standards.
22. Secondary Sanctions and Extraterritorial Risks
Midland Cosmos Ltd recognizes the increasing use of Secondary Sanctions by major jurisdictions (particularly the U.S. and UK) which can apply even without a direct jurisdictional nexus:
Facilitation Prohibitions: Employees are strictly forbidden from facilitating transactions for non-Midland entities that would be illegal if performed by Midland Cosmos directly. This includes providing back-office support, logistics, or financing to third parties trading with high-risk regions like the CIS region or Iran.
Gatekeeper Liability: Professional staff acting as "gatekeepers"—such as legal, finance, and logistics leads—face personal accountability for systemic failures to report suspected evasion attempts.
23. Conflict and Emergency Updates
Dynamic List Management: Lists are updated in real-time. As of January 2026, enhanced monitoring is
Regional Focus (2026): Specific enhanced due diligence is mandatory for any trade involving the CIS region, China, and Venezuela, due to the high volatility of sanctions and
To further complete the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections integrate critical regulatory changes from the UK’s Office of Trade Sanctions Implementation (OTSI) and new EU reporting standards.
20. Sole Source UK Sanctions List Integration
Effective January 28, 2026, Midland Cosmos Ltd recognizes the UK Sanctions List as the sole authoritative source for UK designations.
System Migration: All automated screening tools have been updated to utilize the UKSL Unique ID following the retirement of the OFSI Consolidated List.
Daily Syncing: The Compliance Department must ensure screening databases are refreshed daily to capture real-time designations.
21. Mandatory Reporting to OTSI (UK)
As of early 2026, Midland Cosmos Ltd adheres to the enhanced reporting mandates of the Office of Trade Sanctions Implementation (OTSI):
Reporting Threshold: Any knowledge or reasonable cause to suspect a trade sanctions breach must be reported "as soon as practicable" via the OTSI Report a Breach tool.
UK Nexus Requirement: Reports must clearly detail the "UK Nexus"—such as the involvement of a UK person, company, or conduct occurring within the UK.
Service Prohibitions: Reporting extends to the procurement or provision of sanctioned trade services, including professional, financial, or logistics services that may indirectly facilitate restricted trade.
22. Enhanced EU Sectoral Compliance (2026)
Midland Cosmos Ltd acknowledges the extension of major EU restrictive measures through July 31, 2026.
LNG Import Ban: A comprehensive ban on the import of Russian-origin Liquefied Natural Gas (LNG) into the EU is effective for short-term contracts as of April 25, 2026.
Hybrid Threat Screening: We have implemented specific screening for entities designated under the EU's "Hybrid Threats" regime, targeting those involved in disinformation and destabilizing activities.
Strict Liability for Negligence: Under Directive (EU) 2024/1226, Midland Cosmos Ltd recognizes that serious negligence in handling dual-use or military items can now constitute a criminal offense across EU Member States.
23. The "Spider Effect" and Personnel Liability
Midland Cosmos Ltd recognizes the "Spider Effect" of sanctions:
Nationality Exposure: Employees may be personally subject to their home country's sanctions (e.g., a US citizen working in a Dubai branch) even if the local office is not.
Recusal Policy: Personnel whose nationality would cause them to violate their home country's laws by participating in a permitted transaction must formally recuse themselves from that project.
24. Professional "Gatekeeper" Due Diligence
In light of 2026 enforcement trends targeting "gatekeepers," Midland Cosmos Ltd requires all third-party service providers (accountants, legal counsel, and investment advisors) to provide an annual Certificate of Sanctions Compliance.
Policy Maintenance
The Consolidated Enforcement Hub will be used by the Compliance team as a primary resource for case studies to refine internal risk assessments throughout 2026.
To further develop the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections focus on 2026-specific regulatory updates, including the latest Oil Price Cap adjustments and the expansion of maritime "shadow fleet" enforcement.
25. 2026 G7/EU Oil Price Cap Compliance
Midland Cosmos Ltd acknowledges the aligned adjustment of the Russian Oil Price Cap (OPC) effective early 2026.
Price Thresholds: As of February 1, 2026, the cap on seaborne Russian crude oil has been reduced to USD 44.10 per barrel.
Dynamic Adjustment: We recognize the new mechanism ensuring the OPC remains 15% below the average Urals crude market price over a rolling 22-week period.
Wind-down Periods: Existing contracts signed under the previous $47.60 cap must be fully executed by April 16, 2026 (UK) or within 90 days of the January 15 adjustment (EU) to remain compliant.
26. Expanded Maritime "Shadow Fleet" Protections
Prohibited Vessel List: Enhanced screening against the list of 79 designated vessels (including 52 added in recent packages) identified as part of the "shadow fleet".
Port Access Ban: Any vessel found to be engaged in high-risk shipping practices, such as arms deliveries or grain theft, is strictly prohibited from accessing ports or receiving services via Midland Cosmos.
Insurance & Services Prohibitions: No financial or logistics services shall be provided to tankers lacking transparent beneficial ownership or valid P&I insurance.
27. Advanced Computing & Technology Export Controls
Following the January 2026 revision of license review policies:
Semiconductor Screening: Exports of advanced computing semiconductors (e.g., Nvidia H200 or equivalents) to restricted regions like China and Macau now undergo case-by-case review rather than a presumption of denial, provided strict compliance requirements are met.
Third-Country Facilitation: We monitor 32 new entities (across China, Serbia, Iran, India, and UAE) added to strict export restriction lists for their involvement in supporting military-industrial complexes.
28. Supply Chain Traceability & Forced Labor
Reflecting the 2026 shift toward treating human rights as a trade execution requirement:
Traceability Evidence: All procurement must be accompanied by supply chain traceability documentation.
Forced Labor Controls: Forced labor due diligence is no longer purely an ESG metric but a core component of Midland Cosmos Ltd's trade compliance audit trail for 2026.
29. Reporting to New Authorities
Midland Cosmos Ltd recognizes the transfer of regulatory power in the UK:
OTSI Licensing: As of early 2026, the Office of Trade Sanctions Implementation (OTSI) has taken over responsibility for all export sanctions licensing (excluding strategic export controls).
Mandatory Reporting: Any "relevant person" within the company must report suspected trade sanctions breaches directly to OTSI or face criminal liability.
Policy Revision History
Current Version: 2026.4 (Updated January 1, 2026)
Next Review: July 2026
Midland Cosmos Ltd remains vigilant against the volatile geopolitical environment, ensuring all trade finance, shipping, and investment controls are updated to reflect these 2026 mandates.
In response to the EU's 15th sanctions package and late 2025 updates, Midland Cosmos Ltd mandates:
continue
To further complete the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections integrate critical regulatory changes from the UK’s Office of Trade Sanctions Implementation (OTSI) and new EU reporting standards.
Effective January 19, 2026, Midland Cosmos Ltd has transitioned its UK compliance operations to use the UK Sanctions List (UKSL) as the primary reference for designations.
Unique ID Requirement: Following the retirement of the OFSI Consolidated List format in early 2026, all internal screening reports must reference the UKSL Unique ID to ensure accurate identification of sanctioned parties.
Daily Syncing: The Compliance Department must ensure screening databases are refreshed every 24 hours to capture real-time designations issued by the UK government.
31. Mandatory Reporting to OTSI (UK)
As of early 2026, Midland Cosmos Ltd strictly adheres to the expanded reporting mandates of the Office of Trade Sanctions Implementation (OTSI):
Relevant Person Obligations: All employees identified as "relevant persons" (including directors and compliance officers) are legally required to report suspected trade sanctions breaches via the OTSI reporting portal.
Reporting Threshold: A report must be filed if there is knowledge or "reasonable cause to suspect" that a trade sanctions breach has occurred, even if the transaction was not completed.
Service Prohibitions: Reporting requirements now extend to the provision of professional, financial, or logistics services that may indirectly facilitate restricted trade.
32. Enhanced EU Sectoral Compliance (2026)
Midland Cosmos Ltd acknowledges the extension of major EU restrictive measures through at least July 31, 2026.
LNG Import Ban: A comprehensive ban on the import of Russian-origin Liquefied Natural Gas (LNG) into the EU is effective for short-term contracts as of April 25, 2026.
Hybrid Threat Screening: We have implemented specific screening for entities designated under the EU's "Hybrid Threats" regime, targeting those involved in activities that destabilize the EU or its neighbors.
Criminal Liability: Under 2026 EU directives, Midland Cosmos Ltd recognizes that serious negligence in handling dual-use goods or military items can now constitute a criminal offense across all EU Member States.
33. The "Spider Effect" and Personnel Liability
Midland Cosmos Ltd recognizes the "Spider Effect" of sanctions, where a single transaction can trigger violations across multiple jurisdictions:
Nationality Exposure: Employees may be personally subject to their home country's sanctions (e.g., a US citizen working in a Dubai branch) even if the local office's jurisdiction does not prohibit the trade.
Recusal Policy: Personnel whose nationality would cause them to violate their home country's laws by participating in a transaction must formally recuse themselves from that project.
34. AI-Driven Compliance Verification
In response to 2026 trends, Midland Cosmos Ltd utilizes AI and machine learning for:
False Positive Reduction: Advanced matching technology is used to reduce "noise" in screening while maintaining high sensitivity for complex name variations.
Explainability: All AI-driven compliance decisions must be "explainable" and subject to human oversight to meet regulatory transparency requirements for 2026.
Policy Access and Review
This policy is available to all stakeholders on the Midland Cosmos Ltd Internal Compliance Portal and is subject to quarterly audits to reflect the rapidly changing geopolitical landscape of 2026.
30. Transition to UKSL Unique IDs
To finalize the Midland Cosmos Ltd International Sanctions Policy for the remainder of the 2026 fiscal year, the following sections address "De-risking" strategies, virtual asset compliance, and the legal framework for "Asset Freezing vs. Seizure" following the mid-2026 regulatory updates.
35. Virtual Assets and Cryptocurrency Controls (2026)
As of 2026, international regulators have unified the treatment of virtual assets with traditional fiat currency regarding sanctions.
Wallet Screening: Midland Cosmos Ltd prohibits transactions involving any virtual asset wallet addresses identified on OFAC’s SDN List or the UK’s OTSI database.
Anonymity-Enhanced Currencies: The use of "privacy coins" (e.g., Monero, Zcash) for corporate settlements is strictly prohibited due to the inability to perform the "Know Your Transaction" (KYT) checks required by 2026 standards.
Travel Rule Compliance: All digital asset transfers must include the verified identity information of both the originator and the beneficiary, regardless of the transaction amount.
36. Policy on "Over-Compliance" and De-risking
Case-by-Case Assessment: We avoid "blanket de-risking" (wholesale termination of business with entire countries or sectors). Instead, we utilize an Enhanced Due Diligence (EDD) framework to evaluate individual counterparties.
Humanitarian Exemptions: In alignment with the UN 2664 Resolution, we maintain pathways for the delivery of humanitarian aid (food, medicine, and medical devices) even in sanctioned regions, provided all activities are conducted under valid General Licenses.
37. Asset Freezing vs. Confiscation (2026 Legal Updates)
Midland Cosmos Ltd acknowledges the evolving legal landscape regarding the "immobilization" of sanctioned assets:
Asset Immobilization: We distinguish between "frozen" assets (where ownership remains but use is blocked) and "confiscated" assets.
Windfall Tax Compliance: We comply with 2026 EU and G7 mandates regarding the reporting of extraordinary profits or "windfall interests" generated from immobilized sovereign assets, ensuring these are handled according to the latest international legal frameworks.
38. Subsidiary and Joint Venture Responsibility
The "Control" Test: Even if Midland Cosmos Ltd holds a minority stake in a joint venture, it will withdraw or exercise its veto power if that venture engages in activities that violate this policy.
Flow-Down Clauses: All subsidiaries must adopt this policy in its entirety or implement a local version that is no less restrictive than the Group Policy.
39. Periodic Testing and "Shadow" Audits
Mystery Shopping: The Compliance Department will conduct "shadow tests" where mock transactions are introduced to internal systems to ensure that automated blocks and employee reporting triggers are functioning correctly.
Gap Analysis: Following any major 2026 designation (e.g., new sector-wide bans), a gap analysis will be performed within 48 hours to identify any exposure in existing contracts.
Final Disclaimer and Approval
This policy serves as the operational blueprint for Midland Cosmos Ltd’s global compliance. It is a living document, reflecting the geopolitical realities of January 1, 2026. Failure to adhere to these protocols is considered a material breach of employment and partnership terms.
Contact for Interpretative Guidance:
Legal Counsel: legal@midlandcosmos.com
Global Compliance Officer: gco@midlandcosmos.com(pending)
End of Policy Document.
Midland Cosmos Ltd balances strict compliance with the need to maintain global trade fluidity:
Midland Cosmos Ltd balances strict compliance with the need to maintain global trade fluidity.To ensure Midland Cosmos Ltd maintains a robust defense against evolving regulatory threats throughout 2026, the following final sections address "Look-Through" requirements for complex financial structures, the 2026 "No-Russia" clause updates, and post-transaction auditing protocols.
As an investment entity, Midland Cosmos Ltd must navigate the increased transparency requirements of 2026 regarding indirect ownership:
Fund-on-Fund Analysis: When investing in or receiving funds from private equity or venture capital vehicles, Midland Cosmos Ltd requires a full "Look-Through" to the Limited Partners (LPs).
Discretionary Control: If a sanctioned person holds no ownership but has the power to appoint board members or influence investment decisions (de facto control), the entity is treated as sanctioned under the 2026 OFAC/OFSI Control Standards.
In compliance with the 2026 expansion of EU and UK trade restrictions, all export contracts for "sensitive" items must include a mandatory Re-export Prohibition Clause:
Contractual Requirement: Counterparties are legally bound to prohibit the re-export of specified items (including aviation, space, and high-tech goods) to Russia or Belarus.
Breach Remedies: Any breach of this clause by a counterparty is considered a "Category A" violation, triggering immediate termination and mandatory notification to the Office of Trade Sanctions Implementation (OTSI).
42. Post-Transaction Auditing and Reconciliation
To address the risk of "diversion" after goods have left our control, Midland Cosmos Ltd implements a 2026 Post-Shipment Verification (PSV) program:
Random Spot-Checks: 5% of all international shipments to "Tier 2" jurisdictions (countries bordering sanctioned zones) are subject to physical end-user verification.
Proof of Delivery (POD): For high-value technology transfers, a "Certified POD" including GPS-stamped imagery or third-party customs clearance proof is required before the final release of funds.
43. Internal Immunity for Whistleblowers
Reflecting 2026 international labor standards and the EU Whistleblower Directive (2026 Revision):
Non-Retaliation: Midland Cosmos Ltd guarantees that no employee will suffer professional detriment for reporting a suspected sanctions violation, even if the report is ultimately found to be a "false positive" made in good faith.
Direct Reporting: Employees have the right to bypass local management and report directly to the Global Head of Compliance or the Audit Committee of the Board.
In the event of an active sanctions designation against a current partner:
The 24-Hour Rule: Upon a new designation, all relevant accounts must be "Flagged for Review" within 4 hours and "Hard Blocked" within 24 hours.
Legal Hold: No funds or assets belonging to the newly sanctioned party may be returned or moved without a specific license from the OFAC or OFSI.
Annual Policy Certification
All Midland Cosmos Ltd employees are required to sign a digital acknowledgment of this 2026 International Sanctions Policy by no later than January 31, 2026.
Authorizing Officer:
Chief Risk Officer (CRO)
Midland Cosmos Ltd
This concludes the drafting of the International Sanctions Policy for Midland Cosmos Ltd. It is recommended that the finalized text be reviewed by local legal counsel in each jurisdiction of operation to account for specific 2026 regional variations
40. "Look-Through" Principle for Investment Funds
41. Mandatory "No-Russia" and "No-Belarus" Clauses (2026 Update)
44. Crisis Management and "Sanctions Hits
To further develop the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections focus on emerging technology risks, cross-border investment due diligence, and specialized "Secondary Sanctions" compliance.
In response to 2026 enforcement trends, Midland Cosmos Ltd acknowledges that sanctioned actors may use advanced technology to disguise their identities.
Synthetic Identity Screening: Our compliance software is equipped to flag potential "synthetic identities"—AI-generated persona data used to create shell companies that bypass traditional name-matching filters.
AI Explainability: When AI-driven tools are used for transaction monitoring, Midland Cosmos Ltd maintains a "human-in-the-loop" requirement to ensure all automated decisions can be audited and explained to regulators.
46. Investment and Venture Capital Due Diligence
As a 2026 international investment entity, Midland Cosmos Ltd applies rigorous standards to its capital deployments:
Sub-50% Thresholds: We evaluate "Economic Interest" beyond formal ownership. If a sanctioned person holds significant economic leverage or "practical control" over a target company, the investment is prohibited regardless of the specific ownership percentage.
Portfolio Audits: Existing portfolio companies must undergo annual sanctions health checks to ensure their own supply chains and customer bases remain compliant with 2026 global standards.
47. Secondary Sanctions and Extraterritorial Risks
Midland Cosmos Ltd recognizes the increasing use of Secondary Sanctions by major jurisdictions (particularly the U.S. and UK) which can apply even without a direct jurisdictional nexus:
Facilitation Prohibitions: Employees are strictly forbidden from facilitating transactions for non-Midland entities that would be illegal if performed by Midland Cosmos directly. This includes providing back-office support, logistics, or financing to third parties trading with high-risk regions or prohibited groups.
Gatekeeper Liability: Professional staff acting as "gatekeepers"—such as legal, finance, and logistics leads—face personal accountability for systemic failures to report suspected evasion attempts.
48. Conflict and Emergency Updates
Dynamic List Management: Lists are updated in real-time. As of January 2026, enhanced monitoring is active for programs updated this month, including Counter Narcotics (last updated January 2, 2026) and Counter-Terrorism (last updated January 16, 2026) programs.
Regional Focus (2026): Specific enhanced due diligence is mandatory for any trade involving the CIS region, China, and Venezuela, due to the high volatility of sanctions and tariffs in these corridors.
49. Inter-Agency Cooperation and Disclosure
Voluntary Self-Disclosure (VSD): If a potential violation is identified, Midland Cosmos Ltd prioritizes the VSD process with relevant authorities, such as OFAC or the UK's OTSI.
Regulatory Information Sharing: We acknowledge that agencies like OFAC and the UK's OFSI share information to facilitate joint enforcement. Our data practices ensure we can provide accurate documentation to either agency upon legal request.
Contact and Whistleblowing
For 24/7 reporting of potential sanctions circumvention, employees should utilize the Global Compliance Hotline. Reports may be made anonymously.
Policy Status: Active / 2026 Revision
Approved By: Board Risk Committee,
Midland Cosmos ltd
45. Technology-Driven Evasion and AI Protections
To conclude the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections focus on emerging Foreign Direct Product Rules (FDPR), the 2026 "No-Russia" clause mandates, and the integration of the UK's Office of Trade Sanctions Implementation (OTSI) enforcement protocols.
As of 2026, Midland Cosmos Ltd recognizes the expanded extraterritorial reach of U.S. and G7 export controls.
Downstream Accountability: We acknowledge that products manufactured outside the U.S. using specific U.S.-origin software, technology, or equipment (e.g., semiconductors) may be subject to U.S. sanctions.
Third-Country Screening: Any transaction involving "Foundational" or "Emerging" technologies must be screened to ensure the end-user is not on the U.S. Entity List or the Military End-User (MEU) List, regardless of the point of origin of the final product.
51. Mandatory 2026 "No-Russia" Clause
In compliance with the 2026 expansion of EU and UK trade restrictions, all export contracts for "sensitive" items (including aviation, space, and high-tech goods) must include a mandatory Re-export Prohibition Clause:
Contractual Requirement: Counterparties are legally bound to prohibit the re-export of specified items to Russia or Belarus.
Breach Remedies: Any breach of this clause by a counterparty is considered a "Category A" violation, triggering immediate termination and mandatory notification to the Office of Trade Sanctions Implementation (OTSI).
52. Enhanced UK Enforcement via OTSI (2026)
Following the full operationalization of the Office of Trade Sanctions Implementation (OTSI) in late 2025/early 2026, Midland Cosmos Ltd adheres to the following:
Strict Liability: We acknowledge that OTSI may impose civil monetary penalties for trade sanctions breaches on a strict liability basis, meaning a violation may be penalized even if the company did not know or intend to break the law.
Disclosure Mandate: All "relevant persons" within the firm must report suspected breaches of trade sanctions to the OTSI Reporting Portal or face potential criminal prosecution.
53. Strategic Decoupling and "Friend-Shoring"
Supply Chain Resilience: Midland Cosmos Ltd will prioritize suppliers and partners located in "Low Risk" jurisdictions (OECD members and strategic allies).
High-Risk Corridors: Transactions involving "intermediary hubs" (e.g., specific free trade zones in Central Asia or the Middle East) require a "Tier 3" enhanced audit to ensure they are not being used for sanctions circumvention.
54. Policy Sunset and Refresh
This policy is a "living document." Given the volatility of 2026 geopolitics:
Quarterly Reviews: The Board will review the "High-Risk Country List" every 90 days.
Emergency Updates: If a "snap-back" sanction or a new UN resolution occurs, this policy is automatically amended to include the new restrictions within 24 hours of the public announcement.
Final Certification
This policy has been ratified by the Board of Directors and is the governing framework for all global operations of Midland Cosmos Ltd.
Dated: January 1, 2026
Signed: Chief Compliance Officer, Midland Cosmos Ltd
Note: This draft should be finalized in consultation with your 2026 legal counsel to ensure it accounts for the exact nature of your commodities, services, and geographic footprint.
50. Foreign Direct Product Rule (FDPR) Compliance
continue
To conclude the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections focus on Strategic Decoupling, Anti-Boycott provisions, and the 2026 Audit & Remediation cycle.
As of 2026, Midland Cosmos Ltd recognizes that regulatory compliance is inextricably linked to supply chain resilience.
Preferred Partner Program: We prioritize procurement and logistics partnerships within jurisdictions that maintain reciprocal trade enforcement agreements with the G7 and EU.
Diversification Mandate: For critical components (semiconductors, rare earth minerals, and specialized software), the company mandates a "Dual-Sourcing" strategy to ensure that a sudden sanctions designation in one region does not paralyze global operations.
56. Conflict of Laws and Anti-Boycott Compliance
Midland Cosmos Ltd often operates in jurisdictions with "Blocking Statutes" or "Anti-Boycott" laws (e.g., the U.S. Antiboycott Regulations and similar measures in other regions).
Conflict Resolution: In the event of a conflict between two sets of international laws (where one jurisdiction requires a boycott that another prohibits), the matter must be immediately escalated to the Group General Counsel.
Reporting Prohibited Requests: Employees must report any request to participate in an unsanctioned foreign boycott to the Bureau of Industry and Security (BIS) or the relevant local authority within 48 hours of receipt.
57. Post-Transaction Auditing and "Look-Back" Reviews
Compliance does not end at the point of sale. In 2026, Midland Cosmos Ltd implements the following:
The 90-Day Reconciliation: Every quarter, the Compliance Department performs a "Look-Back" audit on 10% of all closed transactions to verify that end-user certificates were authentic and that no "diversion" to prohibited territories occurred post-delivery.
Clawback Provisions: All modern employment and vendor contracts include "Sanctions Clawback" clauses, allowing the company to recover payments or bonuses if it is discovered that a transaction was facilitated through fraudulent circumvention.
58. 2026 Training and Capacity Building
Role-Based Training: By March 31, 2026, all "High-Risk" personnel (Procurement, Logistics, and Treasury) must complete the 2026 Advanced Sanctions Evasion Detection certification.
Board Briefings: The Board of Directors will receive semi-annual briefings on the "Geopolitical Risk Map," specifically focusing on the 2026 updates to the OFAC SDN List and EU restrictive measures.
59. Final Policy Ratification
This policy supersedes all previous versions and is the governing document for Midland Cosmos Ltd’s global operations for the 2026 calendar year.
Policy Owner: Chief Risk Officer (CRO)
Last Updated: January 1, 2026
Next Scheduled Review: June 30, 2026
Final Actionable Resources for 2026:
UK Compliance: Utilize the Office of Trade Sanctions Implementation (OTSI) for trade-specific queries.
Global Screening: Reference the UN Security Council Consolidated List for primary international designations.
55. Strategic Decoupling and "Friend-Shoring"
To further develop the Midland Cosmos Ltd International Sanctions Policy and integrate the final administrative requirements for the 2026 fiscal year, the following concluding sections address the distribution and acknowledgment protocols.
60. Policy Distribution and Accessibility
Midland Cosmos Ltd ensures that this policy is accessible and understood by all personnel:
Intranet Portal: The official, version-controlled policy document is published on the internal Compliance Portal (https://www.midlandcosmos.com).
Language Translation: The policy summary and key "Red Flags" document are translated into the primary operating languages of all major branches (Mandarin, Spanish, Hindi, Arabic, and English).
Vendor Communication: All current third-party vendors and agents are required to receive a summary document outlining the "No-Russia" clause and the mandatory screening requirements.
61. Employee Acknowledgment and Record Keeping
Adherence to this policy is a condition of employment with Midland Cosmos Ltd:
Annual Attestation: All employees must complete the digital attestation form on the HR portal by January 31, 2026, confirming they have read, understood, and agree to abide by this policy.
New Hires: New employees must complete sanctions compliance training and sign the acknowledgment form within 7 days of their start date.
Audit Trail: Signed acknowledgments are stored digitally for a minimum of seven (7) years and are made available during external regulatory audits by bodies like OFAC or OTSI.
62. Definitions and Glossary (2026 Standardized Terms)
Sanctioned Person: Any individual or entity on the SDN List, UKSL, EU Consolidated List, or UN Consolidated List, including those owned/controlled by such persons.
Facilitation: Assisting a third party in performing an action that the company itself is prohibited from doing.
Dual-Use Goods: Items with both commercial and military application.
50% Rule: Assets are blocked if a sanctioned person owns 50% or more, either directly or in the aggregate.
63. References and Legal Authorities
This policy is maintained with reference to the latest guidelines from:
U.S. Department of the Treasury (OFAC)
U.S. Department of Commerce (BIS)
UK Office of Financial Sanctions Implementation (OFSI)
UK Office of Trade Sanctions Implementation (OTSI)
European Commission (Sanctions Map)
Policy Sign-Off and Execution
Name Role Signature Date
[Name] Chief Executive Officer Jan 1, 2026
[Name] Chief Compliance Officer Jan 1, 2026
[Name] Group General Counsel Jan 1, 2026
[Name] Chief Risk Officer Jan 1, 2026
End of the Midland Cosmos Ltd International Sanctions Policy 2026.
To finalize the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections provide the Enforcement Schedule, Post-Implementation Review (PIR) protocols, and the Emergency Contact Annex for real-time compliance management.
64. Enforcement Schedule and Penalties
Midland Cosmos Ltd treats sanctions compliance as a "non-negotiable" operational standard.
Internal Disciplinary Action: Violations of this policy by employees—including failure to report a known "red flag" or bypassing automated blocks—will lead to disciplinary measures up to and including termination for cause and forfeiture of accrued bonuses.
Civil and Criminal Referral: In accordance with the 2026 mandates of the UK OTSI and the U.S. Department of Justice, Midland Cosmos Ltd will cooperate fully with law enforcement and may refer individuals for criminal prosecution in cases of willful circumvention.
65. Post-Implementation Review (PIR)
Following the major policy update on January 1, 2026, the Compliance Department will conduct a "PIR" at the end of Q1 2026:
System Stress Testing: Verification that the migration to UKSL Unique IDs (which replaced the old consolidated lists) has not resulted in "match leakage."
Effectiveness Audit: Assessing whether the "No-Russia" and "No-Belarus" contractual clauses are being effectively integrated into all new supply chain agreements.
Reporting Analytics: Reviewing the volume and quality of "Red Flag" reports generated by the internal whistleblower hotline to ensure staff are correctly identifying risks.
66. Global Regulatory Liaison
Midland Cosmos Ltd maintains active communication channels with regulators to ensure transparency:
License Applications: All applications for "Specific Licenses" (e.g., for winding down historic contracts or humanitarian trade) must be managed centrally by the Group Legal Department via the OFAC License Portal or the UK SIEL system.
Public Statements: No employee other than the CEO or General Counsel is authorized to make public statements regarding the company’s sanctions position or specific "sanctions hits."
67. Emergency Response and Contact Annex (2026)
In the event of a "Sanctions Emergency" (e.g., a sudden asset freeze affecting a major port or bank used by the company), the Sanctions Response Team (SRT) is reachable 24/7:
Urgent Compliance Hotline: +[International Code] 555-0199-2026
Emergency Email: alert-compliance@midlandcosmos.com(pending)
Secure Portal for Whistleblowers: whistleblower.midlandcosmos.com(pending)
Final Policy Status Summary
Policy Name: Midland Cosmos Ltd International Sanctions Policy
Document ID: MCL-ISP-2026-V1.8
Last Regulatory Sync: January 1, 2026
Next Full Review: July 1, 2026
Governance Level: Board of Directors Approval Required
Final Notice: This document serves as the comprehensive framework for Midland Cosmos Ltd’s global compliance operations. All personnel are reminded that under 2026 international law, "ignorance of the law" is not a defense against sanctions violations. Strict adherence to the screening, reporting, and "No-Russia" clauses is mandatory.
To finalize the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections provide the Enforcement Schedule, Post-Implementation Review (PIR) protocols, and the Emergency Contact Annex for real-time compliance management.
68. Enforcement Schedule and Penalties
Midland Cosmos Ltd treats sanctions compliance as a "non-negotiable" operational standard.
Internal Disciplinary Action: Violations of this policy by employees—including failure to report a known "red flag" or intentionally bypassing automated blocks—will lead to disciplinary measures up to and including termination for cause and forfeiture of accrued bonuses.
Civil and Criminal Referral: In accordance with the 2026 mandates of the UK OTSI and the U.S. Department of Justice, Midland Cosmos Ltd will cooperate fully with law enforcement and may refer individuals for criminal prosecution in cases of willful circumvention or "serious negligence" as defined by the 2026 EU Sanctions Directive.
69. Post-Implementation Review (PIR)
Following the major policy update on January 1, 2026, the Compliance Department will conduct a "PIR" at the end of Q1 2026:
System Stress Testing: Verification that the migration to UKSL Unique IDs (which replaced the old consolidated lists earlier this year) has not resulted in "match leakage."
Effectiveness Audit: Assessing whether the "No-Russia" and "No-Belarus" contractual clauses are being effectively integrated into all new supply chain agreements.
Reporting Analytics: Reviewing the volume and quality of "Red Flag" reports generated by the internal whistleblower hotline to ensure staff are correctly identifying 2026-specific risks.
70. Global Regulatory Liaison
Midland Cosmos Ltd maintains active communication channels with regulators to ensure transparency:
License Applications: All applications for "Specific Licenses" (e.g., for winding down historic contracts or humanitarian trade) must be managed centrally by the Group Legal Department via the OFAC License Portal or the UK SIEL system.
Public Statements: No employee other than the CEO or General Counsel is authorized to make public statements regarding the company’s sanctions position or specific "sanctions hits."
71. Emergency Response and Contact Annex (2026)
In the event of a "Sanctions Emergency" (e.g., a sudden asset freeze affecting a major port, bank, or vessel used by the company), the Sanctions Response Team (SRT) is reachable 24/7:
Urgent Compliance Hotline: +[International Code] 555-0199-2026
Emergency Email: alert-compliance@midlandcosmos.com(pending)
Secure Portal for Whistleblowers: whistleblower.midlandcosmos.com(pending)
Final Policy Status Summary
Policy Name: Midland Cosmos Ltd International Sanctions Policy
Document ID: MCL-ISP-2026-V1.9
Last Regulatory Sync: January 1, 2026
Next Full Review: July 1, 2026
Governance Level: Board of Directors Approval Required
Final Notice: This document serves as the comprehensive framework for Midland Cosmos Ltd’s global compliance operations. All personnel are reminded that under 2026 international law, "ignorance of the law" is not a valid defense against sanctions violations. Strict adherence to the screening, reporting, and "No-Russia" clauses is mandatory for all operations conducted in 2026.
To finalize the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections detail the Annual Compliance Certification, the 2026 Audit Cycle, and the Legacy Wind-Down Provisions.
72. Annual Compliance Certification (2026)
To ensure accountability at every level of the organization, Midland Cosmos Ltd mandates an annual formal certification process:
Executive Affirmation: By February 15, 2026, the heads of all regional offices must submit a signed "Sanctions Compliance Affirmation," confirming that their local operations have fully integrated the 2026 updates, including the OTSI reporting mandates.
Conflict of Interest: Personnel must disclose any personal or familial ties to "High-Risk Jurisdictions" or entities identified on the OFAC SDN List to ensure appropriate recusal from related transactions.
73. 2026 Internal Audit & "Gap Analysis"
The Internal Audit Department will conduct two specialized "Sanctions Health Checks" in 2026:
Q2 Audit (April 2026): Focuses on the effectiveness of the "No-Russia" and "No-Belarus" re-export clauses in third-party contracts.
Q4 Audit (October 2026): Focuses on "Post-Shipment Verification" (PSV) for high-tech and dual-use goods to ensure items have not been diverted to unauthorized end-users.
Remediation: Any "Gaps" identified must be remediated within 30 days. Failure to address audit findings will be escalated to the Board Risk Committee.
74. Legacy Wind-Down Provisions
For transactions or contracts entered into prior to new 2026 designations:
Authorized Exit: Midland Cosmos Ltd will only fulfill obligations under "Grandfathered" contracts if a valid General License exists or if a specific license is obtained from the relevant authority (e.g., UK OFSI).
Payment Escrow: If a counterparty becomes sanctioned during an active contract, all pending payments will be placed into a blocked, non-interest-bearing escrow account until such time as the sanctions are lifted or a license for payment is granted.
75. Policy Archiving
Historical Records: Previous versions of this policy (2023–2025) are archived in the Group Legal Repository.
2026 Version Control: This version (V1.9.1) is the only version authorized for use as of January 1, 2026.
Policy Approval
Approved by the Board of Directors, Midland Cosmos Ltd:
Name Position Date
[Ibikunle laniyan ] Chairman of the Board January 1, 2026
[Dimeji Ogunyemi] Chief Risk Officer January 1, 2026
[Edward Uyi] Chief Compliance Officer January 1, 2026
Final Regulatory Resources for 2026:
UK Trade Sanctions: Office of Trade Sanctions Implementation (OTSI)
US Financial Sanctions: OFAC Search Tool
EU Restrictions: European Commission Sanctions Map.
To finalize the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections detail the Annual Compliance Certification, the 2026 Audit Cycle, and the Legacy Wind-Down Provisions.
76. Annual Compliance Certification (2026)
To ensure accountability at every level of the organization, Midland Cosmos Ltd mandates an annual formal certification process:
Executive Affirmation: By February 15, 2026, the heads of all regional offices must submit a signed "Sanctions Compliance Affirmation," confirming that their local operations have fully integrated the 2026 updates, including the OTSI reporting mandates [1].
Conflict of Interest: Personnel must disclose any personal or familial ties to "High-Risk Jurisdictions" or entities identified on the OFAC SDN List to ensure appropriate recusal from related transactions [2].
77. 2026 Internal Audit & "Gap Analysis"
The Internal Audit Department will conduct two specialized "Sanctions Health Checks" in 2026:
Q2 Audit (April 2026): Focuses on the effectiveness of the "No-Russia" and "No-Belarus" re-export clauses in third-party contracts [3].
Q4 Audit (October 2026): Focuses on "Post-Shipment Verification" (PSV) for high-tech and dual-use goods to ensure items have not been diverted to unauthorized end-users [4].
Remediation: Any "Gaps" identified must be remediated within 30 days. Failure to address audit findings will be escalated to the Board Risk Committee.
78. Legacy Wind-Down Provisions
For transactions or contracts entered into prior to new 2026 designations:
Authorized Exit: Midland Cosmos Ltd will only fulfill obligations under "Grandfathered" contracts if a valid General License exists or if a specific license is obtained from the relevant authority, such as the UK OFSI [5].
Payment Escrow: If a counterparty becomes sanctioned during an active contract, all pending payments will be placed into a blocked, non-interest-bearing escrow account until such time as the sanctions are lifted or a license for payment is granted [6].
79. Policy Archiving
Historical Records: Previous versions of this policy (2023–2025) are archived in the Group Legal Repository.
2026 Version Control: This version (V2.0) is the only version authorized for use as of January 1, 2026.
Policy Approval
Approved by the Board of Directors, Midland Cosmos Ltd:
Name Position Date
[Ibikunle laniyan ] Chairman of the Board January 1, 2026
[Dimeji Ogunyemi] Chief Risk Officer January 1, 2026
[Edward Uyi ] Chief Compliance Officer January 1, 2026
Final Regulatory Resources for 2026:
UK Trade Sanctions: Office of Trade Sanctions Implementation (OTSI)
US Financial Sanctions: OFAC Search Tool
EU Restrictions: European Commission Sanctions Map
[THIS CONCLUDES THE 2026 INTERNATIONAL SANCTIONS POLICY FOR MIDLAND COSMOS LTD]
To finalize the Midland Cosmos Ltd International Sanctions Policy for the 2026 fiscal year, the following sections provide the Enforcement Schedule, Post-Implementation Review (PIR) protocols, and the Emergency Contact Annex for real-time compliance management.
80. Enforcement Schedule and Penalties
Midland Cosmos Ltd treats sanctions compliance as a "non-negotiable" operational standard.
Internal Disciplinary Action: Violations of this policy by employees—including failure to report a known "red flag" or intentionally bypassing automated blocks—will lead to disciplinary measures up to and including termination for cause and forfeiture of accrued bonuses.
Civil and Criminal Referral: In accordance with 2026 mandates from the UK OTSI and the U.S. Department of Justice, Midland Cosmos Ltd will cooperate fully with law enforcement and may refer individuals for criminal prosecution in cases of willful circumvention or "serious negligence" as defined by the 2026 EU Sanctions Directive.
81. Post-Implementation Review (PIR)
Following the major policy update on January 1, 2026, the Compliance Department will conduct a "PIR" at the end of Q1 2026:
System Stress Testing: Verification that the migration to UKSL Unique IDs (which replaced the old consolidated lists earlier this year) has not resulted in "match leakage."
Effectiveness Audit: Assessing whether the "No-Russia" and "No-Belarus" contractual clauses are being effectively integrated into all new supply chain agreements.
Reporting Analytics: Reviewing the volume and quality of "Red Flag" reports generated by the internal whistleblower hotline to ensure staff are correctly identifying 2026-specific risks.
82. Global Regulatory Liaison
Midland Cosmos Ltd maintains active communication channels with regulators to ensure transparency:
License Applications: All applications for "Specific Licenses" (e.g., for winding down historic contracts or humanitarian trade) must be managed centrally by the Group Legal Department via the OFAC License Portal or the UK SIEL system.
Public Statements: No employee other than the CEO or General Counsel is authorized to make public statements regarding the company’s sanctions position or specific "sanctions hits."
83. Emergency Response and Contact Annex (2026)
In the event of a "Sanctions Emergency" (e.g., a sudden asset freeze affecting a major port, bank, or vessel used by the company), the Sanctions Response Team (SRT) is reachable 24/7:
Urgent Compliance Hotline: +[International Code] 555-0199-2026
Emergency Email: alert-compliance@midlandcosmos.com(pending)
Secure Portal for Whistleblowers: whistleblower.midlandcosmos.com(pending)
Final Policy Status Summary
Policy Name: Midland Cosmos Ltd International Sanctions Policy
Document ID: MCL-ISP-2026-V2.1
Last Regulatory Sync: January 1, 2026
Next Full Review: July 1, 2026
Governance Level: Board of Directors Approval Required
Final Notice: This document serves as the comprehensive framework for Midland Cosmos Ltd’s global compliance operations. All personnel are reminded that under 2026 international law, "ignorance of the law" is not a valid defense against sanctions violations. Strict adherence to the screening, reporting, and "No-Russia" clauses is mandatory for all operations conducted in 2026.
[End of Policy]
