Conservative screening, conservative exclusions.
Every party to every transaction is screened against UK, EU, and US sanctions lists and against politically-exposed person lists. Our policy is deliberately stricter than the legal minimum.
Universal screening
Senders, designated payers, and end beneficiaries are screened against the UK Sanctions List, the EU Consolidated List, the OFAC SDN list, and recognised PEP and adverse-media datasets. Screening is performed at onboarding, before each transaction, and continuously against updated lists.
Designated persons — absolute prohibition
Sending funds, directly or indirectly, to or from any designated individual or entity is strictly prohibited. There are no exceptions.
Politically-exposed persons — blanket exclusion
We do not onboard politically-exposed persons or their close associates. Given the risk profile of the corridors we operate in, we believe blanket exclusion is more appropriate than enhanced due diligence.
OFSI engagement
We freeze and block transactions where a sanctions concern arises and report as required to the Office of Financial Sanctions Implementation. Staff training covers obligations under the Sanctions and Anti-Money Laundering Act 2018.
Settlement model
Settlement is performed peer-to-peer, with each leg fully recorded and reconciled. This gives our banking and counterparty partners a clear, auditable picture of every flow on our platform.