Compliance & responsible sourcing
A file is only as good as the questions it can answer.
Metals and minerals moving out of a producing jurisdiction and into processing or export markets attract scrutiny from customs, correspondent banks, refiners and regulators — correctly. We build every file to be examined, not to be waved through.
OFAC and sanctions screening
All counterparties, beneficial owners, agents, vessels, carriers and payment recipients are screened against U.S. OFAC lists and applicable international measures before a transaction opens and again before settlement. We do not transact in embargoed jurisdictions.
BSA / AML and know-your-counterparty
Written identification, beneficial-ownership, PEP and adverse-media procedures, source-of-goods and source-of-funds narratives, recordkeeping, and escalation of red flags to counsel. Payments follow the verified account path — no third-party or nested settlement.
OECD Due Diligence Guidance
Origination is assessed against the OECD five-step framework and Annex II risks — conflict financing, serious human-rights abuse, illegal armed groups, illicit taxation and bribery — across every sector we work in, not only conflict minerals in the traditional sense.
Kimberley Process & sector-specific schemes
Rough diamond consignments are screened and documented under the Kimberley Process Certification Scheme in addition to EKNOX's own origin verification checklist. Battery-mineral consignments are assessed against downstream buyers' responsible-sourcing standards.
FCPA & UK Bribery Act
Working with ministries and state entities creates direct exposure under the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. Every mandate carries anti-bribery representations binding on EKNOX, its partners and any intermediary. Facilitation payments are prohibited absolutely — including the narrow exception the FCPA permits and the UK Act does not.
Third-party vetting
Agents, consultants, expediters and introducers are the commonest bribery channel and are vetted accordingly: beneficial ownership, connection to public officials, justification for the fee, and a written prohibition on onward payments. An intermediary who cannot explain what their fee is for does not get appointed.
Recorded, nominal, lawful
Gifts and hospitality involving public officials are prohibited save for items of genuinely nominal value that are transparent, recorded in the register, and lawful where given. No political contributions are made on behalf of a client or to advance a transaction.
Personal data & retention
Onboarding necessarily collects identity documents, beneficial ownership particulars and screening results. That material is held on the lawful basis of meeting AML and sanctions obligations, restricted to those who need it, retained only for the required period, and then destroyed. It is not stored in the client portal.
What we decline, without discussion
- Metal, ore, concentrate or gemstone parcels with no verifiable licence, export permit or royalty trail
- Safekeeping receipts, "in-ground" reserves or asset-backed paper offered as product or collateral
- Bank guarantees, standby letters of credit and prime bank instruments presented as proof of funds
- Advance payments, "clearance fees", or taxes payable to an individual rather than an authority
- Sellers who will not permit witnessed sampling, assay or grading
- Structures that route title or payment to obscure beneficial ownership
- Documents presented on the letterhead of a state body that the state body cannot confirm
- Any transaction requiring us to be unable to explain it afterwards
Where compliance lives in the file
Four documents, one continuous record.
Compliance is not a memo attached at the end. It is four of the nineteen instruments in the transaction file, produced in the order a diligence officer would actually want to read them.
KYC & Ultimate Beneficial Ownership Questionnaire
Entity identification, beneficial ownership to the natural person, governance, and source of goods or funds.
Licence, Permit & Proof of Origin Verification Checklist
Extraction rights, export authorisation and royalty clearance, verified directly with the issuing authority.
Sanctions, PEP & Adverse Media Screening Record
OFAC, UN, EU and UK list screening plus adverse media review on every named party, re-run before settlement.
OECD Annex II Risk Assessment
The five-step framework applied to the specific origination route, with Category A indicators halting the file until resolved.