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UNITED SUPPLIERS GROUP LIMITED
COMPLIANCE POLICIES

Effective Date: February 02, 2025
Last Updated: May 29, 2025
Next Review: February 01, 2026
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Welcome to United Suppliers Group’s Compliance Policy page.
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United Suppliers Group Limited (“USG”) is a Hong Kong-based consulting company. Although we are not a licensed Trust or Company Service Provider (TCSP) and are not legally required to hold such a license under Hong Kong law, we recognize the importance of strong compliance practices — especially when working with clients from complex jurisdictions.

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We voluntarily follow core AML/CTF and sanctions compliance principles based on FATF recommendations and Hong Kong’s AML guidelines. These measures are designed to protect our partners, clients, and banking providers — and to ensure that our services are used only for legal and transparent business purposes.

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We do not handle client funds and do not act as nominees, company secretaries, or registered agents. Our services are strictly limited to consulting, supplier sourcing and evaluation, market research, business event organisation, project management, and operational support.

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1. Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF) Measures We Apply

We align our policy with FATF Recommendations, the Hong Kong AML Ordinance, and EU AML Directives.

Key measures:

  • Client Identification (KYC): We verify individuals and legal entities using government-issued ID and corporate documentation.

  • UBO Checks: For corporate clients, we identify and verify all UBOs.

  • Risk Rating: Each client is assigned a risk score (low, medium, high) at onboarding, based on their profile.

  • Source of Funds: We request documentation for the source of funds. Payments from third parties are generally not accepted unless pre-approved by Compliance with supporting documentation, a clear link between client and sender, and screening of both parties.

  • EDD: Enhanced due diligence is applied to high-risk clients, PEPs, and flagged jurisdictions.

  • Ongoing Screening: We re-screen clients before each new service engagement or incoming payment.

  • Screening Tools: We use manual reviews and OpenSanctions for initial screening. In complex cases, external KYC/EDD providers are engaged.

  • Training: Annual AML/CTF and sanctions training is provided to all relevant staff.​

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2. Sanctions Compliance

We fully comply with UN, OFAC (U.S.), EU, UK, and HKMA sanctions regulations.

Our principles:

  • Jurisdiction Restrictions: We do not onboard clients from comprehensively sanctioned countries unless:

  1. The activity is clearly permitted under applicable laws and international regulations, and

  2. The client and transaction are screened and approved by our Compliance Officer, CEO and banking partners.

  • Screening: All clients are screened at onboarding and before each transaction.

  • Blocked Persons: We do not engage with entities or individuals on international sanctions lists.

  • Monitoring: Screening is conducted manually and through OpenSanctions. Red flags trigger escalation and external verification.​

  • Right to Refuse or Exit: We reserve the right to terminate any client relationship that presents sanctions-related risk.

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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​​

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All clients and transactions must be approved by the Compliance Officer. Data and documents collected are processed in accordance with our Privacy Policy.

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4. Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

  • CDD: Includes ID verification, UBO check, and business profile review.

  • EDD: Required for PEPs, high-risk industries, or jurisdictions (FATF grey/black). Supporting documents (e.g., tax returns, contracts) are collected.

  • Client Monitoring: Client risk scores and due diligence files are reviewed before each new engagement or payment to ensure continued compliance.

  • Escalation: If concerns arise (e.g. false positives, UBO issues), the matter is escalated to the Compliance Officer. Complex or unresolved issues are further escalated to trusted external compliance partners and the CEO.​​

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5. Whistleblowing & Reporting Concerns

We support transparency and reporting of compliance issues.

  • Reports can be sent to: compliance@usg.world

  • Anonymous reports are accepted.

  • No retaliation policy.

  • Investigations are handled by our Compliance Officer.

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7. Oversight & Review

  • Compliance Officer conducts internal quarterly reviews. Findings are reported to CEO.

  • Random audits are performed.

  • Policy is reviewed annually or upon legal change.

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Contact: compliance@usg.world

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