Ethics & Compliance

Know Your Customer (KYC) Policy

The policy has been designed based on the Joint Money Laundering Steering Group (JMLSG) guidance. In addition, the policy and related controls use resources and recommendations from international standards such as the OECD and UN Principles, as well as Transparency International’s Corruption Perception Index, Know Your Country Rating and Control Risks Corruption Index.

 
Anti‐Bribery & Corruption (ABC) Policy

The policy was designed using resources such as the UK Ministry of Justice and the US Department of Justice guidelines, as well as international standards published by the OECD and the UN. It was designed following an extensive process to map the ABC risks ubhal faces globally, and takes into consideration its activities, countries of operation, the way ubhaltransacts, how it manages its relationships with its intermediaries and its trading counterparties.

 
Sanctions Policy

The principal objective of ubhal’s sanctions policy is to ensure compliance with relevant laws and provide a framework for employees to seek advice from compliance and legal in relation to a transaction or potential transaction. Changes to all relevant sanction regimes, including but not limited to US OFAC, EU Official Journal, Swiss SECO, and UK HM Treasury are monitored and tracked on a daily basis.