Sanctions, anti-money laundering and export control policy

Who it applies to

The policy applies to all Accenti employees and to agents, freight forwarders, customs brokers and partners acting for Accenti, for every client, supplier, payment and shipment.

Key requirements

• Sanctions screening

  Clients, suppliers, agents, consignees and their owners are screened against UN, US, UK and EU sanctions lists before engagement and periodically after.

• Know your counterparty

  The identity, ownership and legitimacy of every counterparty are verified and recorded before engagement, with enhanced checks where risk is higher.

• Clean payments

  Payments move only through regulated banking channels, in the counterparty's own name. Cash is minimized, and third-party payments need Compliance approval.

• Red flags

  Unexplained urgency, missing ownership information, payments from unrelated parties, over- or under-invoicing and unusual routing are reported to Compliance.

• Export and import controls

  Goods, technology and equipment, including dual-use items, are classified, licensed where required and declared accurately to customs.

• Records

  Screening results, due-diligence records, licenses and customs documents are kept for at least five years.

Reference framework

• UN Security Council sanctions, including the Somalia and Al-Shabaab sanctions regime
• Applicable UAE and Somali anti-money laundering and counter-terrorist financing law
• US, UK and EU sanctions and export control regulations, where they apply
• The FATF Recommendations, as guidance