Compliance & Ethics
Uncompromising Integrity.
Compliance is not a department here; it is the precondition of every mandate we accept. We operate strictly within the frameworks that govern international defence trade, and we decline work that cannot meet them.
ITAR
The International Traffic in Arms Regulations govern every controlled item we touch. Licensing precedes movement, without exception, and classification precedes licensing.
FCPA
Zero tolerance for facilitation payments or improper inducement. Every counterparty, agent and consultant is screened, documented and contractually bound.
UN Sanctions
Continuous screening against UN, EU, UK and OFAC designations, with end-user certification and retransfer undertakings held on file for the life of the mandate.
Our standing controls
- Jurisdiction and classification established in writing before engagement.
- End-user and end-use statements obtained, verified and retained for the life of the mandate.
- Counterparty, beneficial-owner and agent screening at onboarding and at defined intervals thereafter.
- No success-fee arrangements with government officials or their connected parties, under any structure.
- Retransfer and re-export undertakings documented before first shipment.
- Audit-ready record keeping, retained in line with the longest applicable retention period.
What we decline
- Any transaction touching a designated party, embargoed destination or restricted end use.
- Engagements where the end user cannot or will not be identified and documented.
- Requests to structure around licensing requirements rather than through them.
- Introductions where a facilitation payment is expected at any point in the chain.
- Mandates outside our registered brokering scope, unless referred to a registered party.
Compliance Overview
Request our compliance overview.
A twelve-page document setting out our screening methodology, licensing sequence, end-user vetting standard and record-keeping practice. Issued to qualified organisations without obligation, and without opening a mandate discussion.