Compliance & Governance

Counterparty Screening & KYC

We establish identity, ownership and commercial credibility before entering a business relationship.

Information requests are proportionate to the relationship and the risks identified.

Certificate of incorporation or registry extract, registered address, directors, authorised representatives and any required licences.

Direct and indirect ownership and ultimate beneficial owners. Unclear structures require further information.

Screened in context. A politically exposed person is not automatically excluded.

The transaction should make commercial sense for the parties' roles, volumes and payment terms. Unexplained third-party payments or unclear intermediary roles trigger review.

Updated checks when ownership, management or transaction structure changes.

Sanctions & AML Compliance

We assess sanctions and financial-crime risk across parties, ownership, vessels, routes and payments.

Lists administered by authorities that apply to the transaction are continuously screened. A name match is assessed in context, and no match does not settle questions of ownership or control.

OFAC UN Security Council EU UK

Authority of the parties, commodity and destination restrictions, payment route, third-party payment instructions and consistency of documents. A payment instrument such as a letter of credit does not by itself establish compliance.

Vessel identity and ownership, voyage history, routing and shipping-document consistency. AIS data informs a review but is not conclusive on its own.

Indicators include unexplained third-party payments, unusual structures, inconsistent documents and unclear beneficial ownership.

Commissions and fees need a legitimate purpose and proper documentation.

Screening results, approvals and correspondence are kept as the law and contracts require.

ESG & Governance

We consider environmental, social and governance risks alongside commercial and regulatory requirements.

Applicable environmental laws, maritime pollution and emissions rules (IMO), and safe handling and transfer. Environmental claims are supported by evidence.

Attention to forced labour, worker safety and supplier conduct where relevant.

Defined approval authority, review of material risks, accurate records and managed conflicts of interest.

Misrepresented availability, unclear intermediary roles or unsupported authority to sell warrant scrutiny. We may ask for clarification or decline to proceed.