AML, CTF & Sanctions Compliance Policy
Risk-based controls intended to prevent company systems, payments or supply chains from being used for money laundering, terrorist financing or prohibited transactions.
View all policies↗What this policy is designed to do.
To establish proportionate screening and payment controls for counterparties, transactions and higher-risk business relationships.
Who it applies to: Finance, procurement, business development, contract owners and personnel involved in supplier onboarding, payments, cross-border logistics or partner selection.
The standards we expect in practice.
These principles guide decisions, conduct and day-to-day execution across the relevant parts of our business.
Use formal and traceable payment channels except where a documented and lawful exception is approved.
Know who we are doing business with and investigate ownership or control where risk warrants it.
Screen relevant parties against applicable restricted-party and sanctions information.
Escalate unusual payment instructions, unexplained third parties or inconsistent transaction patterns.
Do not knowingly support prohibited parties, activities or transactions.
Controls that turn policy into evidence.
Controls are scaled to the nature, value and risk of the activity rather than treated as a one-size-fits-all checklist.
Know-your-partner and vendor onboarding checks.
Beneficial-ownership review for higher-risk counterparties where information is reasonably available.
Sanctions and restricted-party screening at onboarding and when material risk changes.
Payment review, supporting-document requirements and approval controls.
Enhanced due diligence for unusual, complex or high-risk transactions.
Clear ownership matters.
Finance reviews payment integrity and exceptions.
Procurement and business owners collect and validate counterparty information.
Compliance supports enhanced review and escalation of higher-risk cases.
Policies that work together.
Governance controls overlap by design. These related policies provide additional context for this topic.