Accelerating our ambitions
Export control Policy
•
Mandates compliance with all applicable trade control
regulations including the US International Traffic in Arms
Regulations (ITAR) and Export Administration Regulations (EAR),
the UK Export Control Act 2002 as well as trade and economic
embargoes and sanctions
Sanctions: Parties and Transactions Screening Procedure:
Mandates screening against a wide range of categories (from
visitors, to employment candidates, suppliers, customers,
shipping companies)
Uses recognised sanctions screening tool provider which
searches against a broad range of sanctions lists, official and
exclusion lists
•
Is not limited to a particular jurisdiction and includes US and UK
databases/lists
Conducts repeat searches on inputted names
Requires proposed transactions to be reviewed to determine
potential sanctioned country involvement
Requires additional risk based assessments where necessary
Mandates escalation to CCC&R for any positive sanctions
screening hits
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