What is cleared before a trade.

Posture

Controls run before commercial reliance, not after a purchase order is cut. Unverified claims are not treated as facts; a counterparty or a lane that fails a control is not traded with — at any margin. The default is fail-closed.

This statement consolidates the checks a counterparty's compliance or banking team is likely to ask for. It describes the operating posture of the desk, not a certification.

Sanctions screening

Every counterparty and every lane is screened at intake against:

• the EU consolidated financial sanctions list,
• the US OFAC Specially Designated Nationals (SDN) list,
• the UN Security Council consolidated list,
• the UK HMT / OFSI consolidated list, and
• the French Registre national des gels.

Anti-money-laundering and KYC

Counterparties are identified before a commercial relationship begins — legal identity, the company represented, and, where relevant, beneficial-ownership and source-of-funds sensitivity. Records are retained for the period required by French bookkeeping and tax law. Structures or payment routes designed to obscure the counterparty are declined.

Export control and dual-use

Goods are assessed for dual-use classification (EU Regulation 2021/821) and end-use / end-user risk before a quote is circulated. Transactions carrying credible diversion risk, or an end use the desk cannot substantiate, are refused. Specialist counsel is coordinated where a classification is uncertain — never substituted.

Forced labour and origin traceability

Origin traceability and material provenance are documented before reliance, and forced-labour exposure is screened against the applicable frameworks — the US UFLPA and the EU Forced Labour Regulation. Facilities credibly associated with forced labour or with material-origin obfuscation are not engaged.

Destination obligations

Destination-specific regulatory obligations are coordinated as part of the RFQ, not discovered at the port — among them CBAM, EUDR, REACH, CE / UKCA, BIS FMCS, SABER, ACI Nafeza, CPCB EPR, and CITEO, according to the lane.

Governance and scope

Every control leaves a documentation trail, and commercial liability under an engagement is governed by that engagement's contract and by the professional liability cover the company holds. The desk does not act where regulatory exposure exceeds an engagement's commercial scope, and does not provide tax, legal, or customs advice in place of qualified counsel.

Compliance queries can be addressed to contact@bonategia.com.