UNITED SUPPLIERS GROUP LIMITED
COMPLIANCE POLICIES
Effective Date: February 02, 2025
Next Review: February 01, 2026
Welcome to United Suppliers Group’s Compliance Policy page.
Legality is one of our core values. We understand that focus on clients from countries often overlooked by others requires an extra level of responsibility. We thoroughly check every client and their business activity ourselves, and we help our clients build businesses fully compliant with international financial, legal and ethical standards — including AML, CTF, and sanctions laws.
1. Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF)
We align our policy with FATF Recommendations, the Hong Kong AML Ordinance, and EU AML Directives.
Key measures:
• Client Identification (KYC): We verify all clients (individuals and entities) using government-issued ID and corporate documents.
• UBO Checks: For legal entities, we identify and verify ultimate beneficial owners and assess ownership/control structures.
• Risk Rating: Each client is rated as low/medium/high risk at onboarding, and re-evaluated periodically.
• EDD: Enhanced due diligence is applied to high-risk clients, PEPs, and complex jurisdictions.
• Transaction Monitoring: Ongoing screening of payments that we receive from our clients to see for red flags and deviations from expected behavior. We do not handle client funds.
• Suspicious Activity Reporting: Any suspicious activity is escalated to authorities promptly.
• Recordkeeping: Records are kept for 5 years (meeting HK AML Ordinance and GDPR requirements).
• Staff Training: All staff complete annual AML/CTF training, covering sanctions, PEPs, and reporting obligations. High-risk teams (business development) receive additional sessions.
2. Sanctions Compliance
We fully comply with UN, OFAC (U.S.), EU, UK, and HKMA sanctions regulations.
Our principles:
• Screening: All clients, partners and transactions are screened at onboarding and weekly thereafter against consolidated sanctions lists.
• Jurisdiction Restrictions: We do not serve clients from comprehensively sanctioned jurisdictions or entities from high-risk jurisdictions unless:
a) The activity is clearly permitted under applicable laws and international regulations, and
b) The client and transaction are screened and approved by our compliance team and banking partners.
• Blocked Persons: We do not serve individuals or entities listed on sanctions watchlists.
• Ongoing Monitoring: We regularly monitor official sanctions lists (e.g. OFAC, UN, EU) using automated tools and manual reviews.
• Internal Controls: Random audits and quarterly compliance checks.
• Right to Refuse or Exit: We reserve the right to terminate any client relationship that presents sanctions-related risk.
3. Risk Statement
We only work with clients committed to legal, transparent, accountable and responsible business.
We do not work with:
• Individuals or entities attempting to bypass international sanctions or restrictions
• Clients engaged in illegal trade, dual-use goods, arms, or unlicensed crypto activity
• Shell companies with no legitimate operations or nominee UBO structures
• Clients unwilling to disclose beneficial ownership or source of funds
• Clients who avoid compliance obligations
4. Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)
We assess each client’s background, industry, jurisdiction, and transaction profile to manage risk effectively.
• CDD: Applied to all clients. Includes ID verification, business activity check, and transaction profile.
• EDD: Triggered for PEPs, high-risk industries (crypto, international trade), or jurisdictions (FATF grey/black lists). Includes deeper UBO checks, enhanced monitoring and senior approval. For PEPs and high-risk clients, we verify the legitimacy of their wealth through documents (e.g., tax returns, business contracts).
5. Data Protection & Privacy
We follow GDPR and Hong Kong’s PDPO standards.
• We collect and store only necessary data, with client consent.
• Access is limited, encrypted, and logged.
• Data is not shared unless required by law.
• After 5 years (or as required), records are anonymized or deleted.
6. Conflicts of Interest
We are independent and objective in our advice.
• Team members must disclose personal or financial interests in any client-related matter.
• Duties are reassigned or actions taken to mitigate any conflict.
7. Whistleblowing & Reporting Concerns
We support transparency and reporting of compliance issues.
• Concerns can be reported confidentially to: compliance@usg.world
• Anonymous reports are accepted.
• Whistleblowers are protected from retaliation.
• Investigations are handled promptly by our Compliance Officer.
8. Oversight, Audit & Policy Review
• The Compliance Officer oversees implementation and reports to management.
• The Compliance Officer conducts quarterly audits, reviewing a sample of client files, sanctions screening logs, and whistleblower reports. Findings are reported to CEO.
• Policy is reviewed annually or upon legal/regulatory changes.
• Staff are trained and informed after each update.
Questions?
Contact our Compliance Officer at compliance@usg.world