Sanctions and restricted-party policy

We do not knowingly facilitate transactions that would violate applicable sanctions, export controls or restrictions on dealings with prohibited parties or territories. Depending on the transaction, screening may cover counterparties, beneficial owners, directors, representatives, banks, source of funds and relevant jurisdictions. We may request additional declarations, suspend discussions or refuse service where a sanctions or legal concern arises. Screening results require appropriate review; name matches are not conclusive without assessment. Clients and counterparties remain responsible for their own compliance obligations and independent advice.