KYC / AML / sanctions policy.
Buyers and sellers must pass KYB / KYC, sanctions screening, beneficial ownership checks, and transaction-purpose review before accessing private data rooms or transaction workflow.
Corporate registration, beneficial ownership above 25%, directors, regulated-entity status.
OFAC, UN, EU, UK, AUSTRAC, and host-country lists at onboarding and on transaction trigger.
Politically-exposed-person screening for beneficial owners and directors.
Each buyer engagement requires a stated purpose (voluntary retirement, contribution claim, Article 6 use, etc.).
Required for transactions above thresholds set in the engagement letter.
Re-screen on material change, on each new transaction, and at minimum annually.
Sanctioned parties, undisclosed beneficial owners, suspected greenwashing intent, or any sanctions-evasion pattern.