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ÉGÉLYSÉEGLOBAL TRADE

Legal

Compliance & AML

Our approach to anti-money-laundering, sanctions screening, customs discipline and financial crime prevention.

Placeholder wording. This page sets out the structure and covers the usual ground, but it has not been drafted or reviewed by a solicitor. Have it checked against the company’s actual practices before the site goes live.

01

Our position

Élysée Global Trade Ltd operates a risk-based compliance framework aligned to UK anti-money-laundering and counter-terrorist financing expectations, and to the customs and sanctions obligations that apply to international trade.

Compliance is treated as a commercial function rather than a formality. A transaction that cannot be evidenced, classified and screened is a transaction we do not take on.

02

Customer due diligence

Before we trade with a new counterparty we carry out proportionate due diligence, and we refresh it periodically thereafter.

  • Verification of corporate identity, registration and trading address.
  • Identification of beneficial ownership and control.
  • Confirmation of the counterparty's line of business and the commercial rationale for the transaction.
  • Screening against sanctions, politically exposed person and adverse media sources.
  • Enhanced due diligence where the counterparty, jurisdiction or goods present elevated risk.
03

Sanctions and export control

Every counterparty, vessel, route and destination is screened against applicable UK, EU, US and UN sanctions regimes before goods move. Dual-use and controlled goods are identified at classification stage, and licences obtained where required.

We will not facilitate any transaction that we reasonably believe would breach a sanctions measure or an export control, regardless of its commercial value.

04

Customs compliance

Correct classification, valuation and declaration of origin are handled before despatch rather than at the border. We maintain the records required by customs authorities, including for goods held under a customs warehousing regime.

  • HS classification reviewed against the current tariff at the point of order.
  • Customs valuation prepared on a defensible basis with supporting documentation.
  • Preferential origin claimed only where the rules of origin are properly met and evidenced.
  • Full audit trail retained for the statutory period.
05

Bonded warehousing controls

Goods held under a customs warehousing regime are subject to strict stock records, reconciliation and reporting. Duty and import VAT are accounted for correctly at the point goods enter free circulation, and re-exports are evidenced so that no liability arises.

06

Payments and source of funds

We accept payment only through traceable banking channels from an account in the name of the contracting counterparty. Third-party payments, cash settlement and unexplained routing through unrelated jurisdictions are not accepted.

Where the source of funds cannot be satisfactorily established, the transaction will not proceed.

07

Reporting and escalation

Staff are trained to identify indicators of financial crime and to escalate concerns internally without alerting the counterparty. Where a suspicion arises, it is reported to the National Crime Agency in accordance with the Proceeds of Crime Act 2002, and the transaction is suspended pending the outcome.

08

Anti-bribery

We prohibit the offering, giving, requesting or accepting of any bribe or facilitation payment, in accordance with the Bribery Act 2010. This applies equally to employees, agents and third parties acting on our behalf, in every jurisdiction in which we operate.

09

Governance and review

Responsibility for compliance sits with senior management. Policies, screening tools and risk assessments are reviewed periodically and following any material change in law, sanctions regime or business activity.

Concerns about this framework, or about a specific transaction, can be raised with us using the contact details on this site.