Our stance
Environmental certificate markets move quickly. Criminals like fast-moving markets.
That means AML cannot be a background process — it has to be a front-line discipline.
We take a zero-tolerance approach to money laundering, terrorist financing, and any attempt to use certificate trading to disguise the flow of funds.
This statement explains how we prevent it.
1. Know Your Counterparty (KYC)
Before we onboard a counterparty, we verify:
- legal name
- registration details
- incorporation documents
- directors and beneficial owners
- trading history
- sanctions exposure
- geographic risk
- registry accounts
- corporate website, footprint, and legitimacy
If information cannot be verified, we do not trade.
2. We identify the ultimate beneficial owner
We require full disclosure of:
- beneficial owners
- controlling individuals
- authorised signatories
- anyone with significant influence
Shell structures, opaque trusts, and unexplained nominees are red flags.
If ownership cannot be clarified, onboarding stops.
3. We screen all counterparties against global sanctions lists
Including:
- UK OFSI
- UN sanctions
- EU sanctions
- US OFAC
- Local sanctions lists (if relevant to the jurisdiction)
Sanctioned individuals or entities are prohibited from all activity.
There are no exceptions.
4. We understand the nature of your business
We ask for information about:
- markets you operate in
- certificate schemes you use
- expected volumes
- expected transaction sizes
- payment methods
- source of funds
- purpose of certificates
AML control is impossible if we don’t understand what “normal” looks like.
5. We monitor ongoing activity
We continuously review:
- unusual price movements
- abnormal volumes
- repeated cancellations or amendments
- transfers inconsistent with business patterns
- mismatched registry details
- payment delays or routing changes
If something looks odd, we pause trading, investigate, and request clarification.
6. Red flags — we act immediately
We suspend and investigate if we detect:
- large transactions inconsistent with stated activity
- counterparties unwilling to provide information
- payments from unrelated third parties
- use of multiple offshore accounts
- attempts to bypass onboarding
- pressure to accelerate settlement
- inconsistent or unverifiable certificate data
Suspicious activity is reported to the appropriate authority without notice.
7. No cash. No anonymous payments. No crypto.
We only accept:
- bank transfers from named corporate accounts
- settlement from pre-approved entities
We do not accept:
- cash
- third-party payers
- payments routed through high-risk jurisdictions
- unapproved digital wallets
- cryptocurrency settlements of any kind
If we don’t know where funds come from, we do not touch them.
8. Staff training
Everyone involved in onboarding, trading, operations or payments receives:
- AML training
- sanctions training
- fraud detection guidance
- escalation procedures
- scenario-based exercises
Competent people prevent bad transactions before they happen.
9. Independent audits
We conduct periodic reviews by external specialists to confirm:
- our controls work
- our records are complete
- our processes match global AML standards
- our risk assessments are up to date
We welcome scrutiny.
10. Record keeping
We maintain evidence of:
- onboarding
- KYC
- beneficial ownership
- sanctions checks
- transaction history
- trade confirmations
- payment trails
- communications
Records are retained to meet and exceed regulatory requirements.
11. Reporting suspicious activity
If you see something that looks like money laundering or terrorist financing:
Email: compliance@energymarketingandtrading.com
Anonymous reporting: [secure link]
Reports are investigated immediately.
There is no retaliation against whistleblowers.
Why this matters
Money laundering destroys trust.
Trust is the foundation of certificate markets.
Our commitment is simple:
No one uses us to hide money.
Not now. Not ever.