Sanctions Compliance Policy

GCI will not facilitate, participate in or benefit from any transaction that breaches applicable sanctions, export control or trade restriction laws, and will not assist any party in evading them.

Sanctions compliance takes precedence over commercial interest. Where doubt exists, the transaction does not proceed until the doubt is resolved.

• United Nations Security Council consolidated sanctions list.
• Australian Autonomous Sanctions and the DFAT Consolidated List.
• United States OFAC Specially Designated Nationals and sectoral sanctions lists.
• United Kingdom OFSI consolidated list.
• European Union consolidated financial sanctions list.
• Politically exposed person (PEP) databases and adverse media sources.
• Relevant local restrictions in countries of origin, transit and destination.

• The counterparty entity, its trading names and predecessors.
• Directors, authorised signatories and ultimate beneficial owners.
• Introducers, agents and intermediaries in the chain.
• Banks, correspondent banks and payment routes.
• Refiners, assayers, inspection agents, carriers, freight forwarders and insurers.
• Countries of origin, transit and destination, and the routing itself.

Screening is performed at onboarding before any introduction or pricing release, again before execution of a sale and purchase agreement, before payment and shipment, and periodically for the life of the relationship.

Screening is repeated whenever ownership, banking, routing or jurisdiction changes, and when sanctions lists are materially updated.

Any potential match stops the transaction immediately. The match is reviewed against identifying data to determine whether it is a false positive, and the analysis and outcome are documented.

A confirmed or unresolved match results in refusal or termination of the engagement. Where a designated person or entity is involved, we take legal advice on any freezing, reporting or notification obligation before taking further steps, and we do not tip off the counterparty where prohibited.

Transactions must comply with export permit, licensing, royalty, customs and import requirements in the countries of origin, transit and destination. Documentation must be genuine and consistent across the chain.

We will not participate in transhipment, re-labelling, mixed-origin blending or documentation practices designed to disguise origin, ownership, value or destination.

Our agreements require each party to warrant that it is not a sanctions target, that it is not acting for or on behalf of a designated person, and that it will comply with applicable sanctions and export control laws.

Breach of these warranties entitles GCI to suspend or terminate immediately, without liability, and any commercial consequences fall on the party in breach.

Screening searches, results, review notes and decisions are recorded and retained for at least seven years alongside the KYC file.

The Director is accountable for this policy, approves all escalations, and reviews the policy at least annually with input from qualified legal counsel as sanctions regimes change.

Screening is conducted using commercially available list data and public sources. It reduces, but cannot eliminate, sanctions risk. Publishing this policy does not imply that GCI is licensed, registered, supervised or approved by any sanctions authority, and counterparties remain responsible for their own sanctions compliance.