Sanctions & Restricted Counterparties Policy

Purpose

Environmental certificates flow across borders, markets, registries, and jurisdictions.
Sanctions risk is therefore not theoretical — it is live, continuous, and capable of shutting down a business overnight if mishandled.

This policy explains:

  • who we can and cannot trade with
  • which sanctions regimes we follow
  • how we screen counterparties
  • what happens when a risk is detected
  • how we protect the integrity of our trading network

We operate a zero-tolerance approach.
If it’s not clean, we don’t touch it.

1. Sanctions regimes we comply with

We comply with the following major regimes, at a minimum:

  • UK OFSI (Office of Financial Sanctions Implementation)
  • EU sanctions
  • UN Security Council sanctions
  • US OFAC (Office of Foreign Assets Control)
  • Local sanctions relevant to the jurisdiction of the trade

Where two regimes conflict, we apply the most restrictive interpretation.

2. Who we absolutely cannot trade with

We do not trade with:

  • individuals or entities on any sanctions list
  • entities owned or controlled (directly or indirectly) by sanctioned persons
  • entities acting on behalf of sanctioned persons
  • companies located in sanctioned countries where business is prohibited
  • counterparties using nominee structures to disguise sanctioned involvement
  • entities attempting to bypass sanctions through intermediaries
  • any counterparty who refuses to disclose beneficial ownership

If beneficial ownership or control cannot be verified, onboarding stops immediately.

3. Screening obligations

All counterparties are screened at:

  • onboarding
  • renewal
  • each material change of ownership
  • regular periodic intervals
  • the point of every trade

We screen for:

  • sanctions listings
  • PEP (politically exposed person) status
  • adverse media
  • enforcement actions
  • high-risk jurisdictions
  • terrorism financing associations
  • fraud or corporate crime flags

Screening is logged, timestamped, and auditable.

4. Ongoing monitoring

Sanctions exposure can change overnight.

We continuously monitor for:

  • newly listed individuals or companies
  • changes in ownership structure
  • mergers and acquisitions
  • legal actions or regulatory enforcement
  • shifts in geopolitical risk
  • suspicious payment routing
  • abnormal trading patterns

If anything changes, risk is reassessed immediately.

5. Geographical risk

We apply enhanced scrutiny when dealing with counterparties in:

  • high-risk or sanctioned jurisdictions
  • countries with weak AML or corporate transparency standards
  • regions known for document fraud or nominee structures
  • locations commonly used for sanctions evasion routes

Trading with entities in these regions requires explicit approval from compliance.

6. Payments & settlement restrictions

To prevent sanctions breaches:

  • we only accept payments from approved, named accounts
  • we do not accept third-party payments
  • we do not accept payments via high-risk jurisdictions
  • we do not accept crypto, digital wallets, or anonymous transfers
  • we verify bank ownership and location
  • we confirm the purpose and origin of funds when required

Suspicious payment patterns trigger immediate investigation.

7. Red flags requiring escalation

We escalate and pause activity if we detect:

  • reluctance to disclose beneficial owners
  • inconsistent corporate documents
  • payments routed through offshore tax havens without explanation
  • requests to alter documentation
  • mismatched addresses, registration numbers, or identities
  • communications from personal email accounts only
  • sudden changes to bank details
  • pressure to complete trades urgently without due diligence

If it feels like an attempt to hide something, we treat it as one.

8. Restricted counterparties list (RCL)

We maintain an internal list of:

  • prohibited counterparties
  • high-risk entities
  • entities pending further review
  • organisations linked to fraud or misconduct
  • entities flagged by registries or authorities

The list is reviewed and updated continuously.
All onboarding and trade activity is checked against it.

9. What happens when a potential match is found

If a hit is confirmed or cannot be disproven:

  • all activity stops
  • counterparties are notified only if appropriate
  • a formal investigation begins
  • legal and regulatory obligations are followed
  • authorities may be informed
  • the relationship is terminated where required

We will always choose caution over speed.

10. Staff training

All staff involved in:

  • trading
  • onboarding
  • payments
  • operations
  • compliance

…receive sanctions and restricted-counterparty training, including:

  • identifying evasion techniques
  • escalation procedures
  • document verification
  • recognising ownership red flags
  • handling urgent high-risk situations

Competence prevents breaches.

11. Record keeping

We maintain:

  • complete screening logs
  • onboarding documents
  • communication history
  • payment trails
  • registry evidence
  • investigations and outcomes

Records are retained to meet regulatory and audit requirements.

12. Reporting concerns

If you suspect a sanctions issue or restricted counterparty:

Email: [compliance inbox]
Anonymous reporting: [secure link]

Every concern is investigated.
Retaliation is prohibited.

Why this matters

Sanctions breaches:

  • shut down businesses
  • freeze assets
  • trigger investigations
  • undermine counterparties
  • damage registry access
  • erode trust
  • destabilise certificate markets

A clean sanctions posture is not optional — it is essential.

Our position is simple:
We only trade with counterparties we can defend to a regulator, a client, and a newspaper headline.

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