No, the sanction does not apply if an RSPO member acquires an area that was developed by a non-RSPO member, even if the planting happened after the 1 January 2010 cut-off date. However, if the RSPO member continued land clearing after the acquisition without following the NPP process, the sanction will apply. If land clearing is still happening under its control, all operations must stop immediately, and NPP requirements must be met for any unconverted or uncleared areas.