Compliance framework

Controls integrated
at transaction level

AYYS builds compliance into every transaction — not as a procedural layer added afterward, but as a precondition for engagement. Our framework covers KYC, AML, international sanctions, OECD conflict minerals due diligence, EU CBAM and trade documentation integrity. No transaction proceeds without cleared counterparties, documented origin and compliant structure.

KYC & AML

Know Your Counterparty — full beneficial ownership

KYC / AML
FATF 40 Recommendations
EU AMLD6
French Sapin II

Counterparty onboarding procedure

AYYS applies enhanced due diligence to all new counterparties — both buyers and sellers — before any commercial discussion proceeds. The KYC process identifies the legal entity, its beneficial owners to natural person level, the source of funds and the intended end use of the material. For high-risk jurisdictions (DRC, Iran, certain CIS states), enhanced DD is triggered automatically regardless of transaction size.

  • Legal entity verification — registration documents, articles of association, directors
  • Ultimate Beneficial Owner (UBO) identification to natural person level (threshold: 25%)
  • Source of funds and source of wealth documentation for high-risk counterparties
  • PEP (Politically Exposed Person) and adverse media screening via commercial database
  • Ongoing monitoring — annual refresh for active counterparties, event-triggered for adverse developments
  • Transaction monitoring — flags for unusual volumes, atypical payment structures, jurisdiction mismatches
Sanctions

Multi-regime screening before every commitment

Sanctions
OFAC (US)
EU Consolidated List
UN Security Council
UK OFSI
SDFM (France)

Sanctions screening protocol

AYYS screens all counterparties — buyers, sellers, freight forwarders, port agents, vessel operators and flag states — against the four principal sanctions regimes before any transaction is committed. Screening is conducted at mandate initiation, at contract signing and at every material change in transaction structure (new vessel, new port, change of beneficial ownership). AYYS does not rely solely on automated screening: complex or borderline cases are escalated to external legal counsel.

  • OFAC SDN, Sectoral Sanctions Identifications and CAATSA designations
  • EU Consolidated Financial Sanctions List — updated daily, applied to all EU-nexus transactions
  • UN Security Council Consolidated Sanctions List
  • UK OFSI Consolidated List — applies regardless of transaction currency
  • Vessel, flag and port screening for shipping transactions
  • Secondary sanctions analysis for Iranian-origin transactions — OFAC General License review
  • Escalation to external counsel for any SDN-adjacent or complex jurisdictional exposure
OECD Due Diligence

Conflict minerals — 5-step framework

OECD DD
OECD Guidance
3TG + Cobalt
EU Conflict Minerals Reg.
Dodd-Frank 1502

Conflict minerals due diligence — DRC and high-risk areas

For all material originating from the Democratic Republic of Congo, Zambia and other Conflict-Affected and High-Risk Areas (CAHRAs), AYYS applies the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. This covers copper, cobalt, gold, tantalum, tin, tungsten and lithium sourced from or transiting affected regions.

  • Step 1: Strong company management systems — internal policy, supplier code, alert mechanism
  • Step 2: Identify and assess risk — mine-level origin documentation, supply chain mapping to smelter/refiner
  • Step 3: Design and implement a strategy to respond to identified risks
  • Step 4: Independent third-party audit of supply chain DD — applied to Tier 1 suppliers annually
  • Step 5: Report on supply chain DD — summary available to mandate clients on request
  • ITRI Tin Supply Chain Initiative (iTSCi) tagging for 3T minerals from DRC where applicable
  • Chain of custody documentation from mine/processing site through to final delivery
EU CBAM & Trade Documentation

Carbon border adjustment & documentary integrity

EU CBAM
Reg. (EU) 2023/956
Transitional phase 2023–25
Full phase from 2026

Carbon Border Adjustment Mechanism

The EU CBAM applies to copper, aluminium, steel, fertilisers, hydrogen and electricity imported into the EU. From 2026, importers must purchase CBAM certificates corresponding to the carbon price embedded in production. AYYS provides embedded CO₂ intensity data for applicable metal imports on request, and structures documentation to support CBAM declarations.

  • Embedded CO₂ intensity reporting for copper cathode, rod and concentrate
  • Aluminium scrap and ingot — production method and grid emission factor documentation
  • Support for importer CBAM declaration filing
  • Ongoing monitoring of CBAM scope extensions to additional metal categories
Documentation
UCP 600 (L/C)
Incoterms 2020
ICC Arbitration
English Law

Trade documentation standards

All AYYS transactions are documented to international trade standards. L/C transactions follow UCP 600 and eUCP. Contracts are governed by English law with ICC arbitration as the default dispute resolution mechanism. Documentary presentations are reviewed internally before presentation to avoid discrepancies that delay payment.

  • SWIFT MT700 L/C aligned with UCP 600 — all doc requirements agreed pre-issuance
  • Bill of Lading (OBL) — 3/3 originals released against L/C or TT as agreed
  • Certificate of Origin — EUR.1, Form A, or fully commissioned commercial COO
  • Inspection certificate — SGS/Intertek/BV — weight survey + quality analysis
  • Marine insurance — Institute Cargo Clauses (A), all-risks, warehouse-to-warehouse
  • Contracts — English law, ICC Paris arbitration, 30-day notice for disputes
Compliance

Compliance documentation on request

AYYS provides counterparty qualification summaries, OECD DD reports and CBAM data to mandate clients. Contact our compliance team for access.

Contact compliance team → About AYYS