Compliance and Sanctions
How Skyocean screens counterparties, goods and jurisdictions, and what we will not do.
Our position
Skyocean operates a structured compliance framework across every trade we execute. We screen counterparties, goods, vessels and jurisdictions before committing capital, and we decline business that does not clear that screening.
Compliance is a gate in our trade workflow, not a statement of intent. A trade that fails screening does not proceed, and the verification record for every trade is built so that a bank, auditor or regulator can reconstruct what was checked and when.
What we screen against
Before any trade is committed, we screen against the sanctions and restricted-party regimes applicable to the parties, goods and routes involved. These include:
| Regime | Source |
|---|---|
| United States | OFAC Specially Designated Nationals and Blocked Persons List, sectoral and programme-specific measures, BIS Entity List |
| European Union | Consolidated list of persons, groups and entities subject to EU financial sanctions, and applicable sectoral measures |
| United Nations | UN Security Council Consolidated List |
| United Kingdom | OFSI Consolidated List |
| Local | The sanctions, export control and import licensing regimes of each jurisdiction in which a given trade is originated, transited or delivered |
Screening covers the counterparty, its beneficial owners and controllers, the consignee, the carrier and, where relevant, the vessel and its ownership.
What we check on every trade
| Check | What it covers |
|---|---|
| Counterparty due diligence | KYC and KYB on buyers, suppliers and agents, including beneficial ownership, control and politically exposed person status |
| Restricted party screening | All parties to the transaction, refreshed rather than checked once at onboarding |
| Goods classification | Whether the commodity is subject to export control, dual-use restriction, licensing or prohibition in any jurisdiction on the route |
| Permits and certificates | That required export permits, import authorisations, health and phytosanitary certificates and certificates of origin are held and valid before shipment |
| Route and jurisdiction | Origin, transit and destination screened for applicable restrictions, including where goods pass through a third country |
| Document verification | Trade documents cross-checked against independent sources, with discrepancies flagged before shipment rather than after |
| Payment channel | Settlement routed only through banking channels that accept the transaction on disclosed terms |
What we will not do
Stated plainly, because it is more useful than a general assurance:
- We do not transact with sanctioned or restricted parties, or with entities owned or controlled by them
- We do not trade goods that are prohibited, or that require a licence we do not hold
- We do not structure transactions to obscure the origin, destination, ownership or nature of goods, or to avoid the application of any sanctions regime
- We do not accept payment in forms or through channels that would breach applicable restrictions
- We do not proceed where beneficial ownership cannot be established
- We do not proceed where required permits or certificates are absent, expired or inconsistent with the shipment
Where a trade is capable of being executed lawfully only under a licence or authorisation, we obtain it before proceeding, or we decline the trade.
Humanitarian and essential goods
Many of the markets we serve are subject to sanctions regimes that expressly exempt or license food, medicine and medical supplies. We rely on those exemptions only where they clearly apply, and we document the basis on which we rely on them.
An exemption for a category of goods is not an exemption from counterparty screening. Food and medicine trades are screened to the same standard as any other, and the end user is diligenced regardless of the humanitarian character of the cargo.
Verification as compliance evidence
Skyocean’s verification infrastructure exists to make trades auditable, and that record is directly useful for compliance.
For each trade we retain a structured record of the parties, the goods, the documents relied on, the checks performed and the point at which each was completed. Discrepancies between documents are flagged automatically. The effect is that our compliance position on any given trade can be examined after the fact rather than asserted.
This is a record-keeping and control capability. It does not substitute for legal advice, for a licence, or for the judgement of a compliance officer.
Governance
Compliance decisions sit with named individuals, not with software. Trades that raise a sanctions, export control or licensing question are escalated for review and, where appropriate, referred to external counsel in the relevant jurisdiction before proceeding.
We keep our screening lists and jurisdictional analysis current, and we re-screen counterparties over the life of a relationship rather than relying on onboarding checks alone.
Limitations
We state these because a compliance page that claims perfection is not credible.
Sanctions regimes change frequently and sometimes without notice. Screening reduces risk; it does not eliminate it. Our framework is designed to identify and prevent prohibited transactions, to escalate uncertainty rather than resolve it commercially, and to document our reasoning. Where we identify that we have entered a transaction that should not have proceeded, we stop it, and we report it where reporting is required.
Nothing on this page is legal advice, a representation that any particular transaction is permitted, or a warranty of compliance outcome.
Contact
Compliance questions, including counterparty due diligence requests and requests for our screening policy, can be directed to [email protected].
To report a suspected breach, contact the same address. Reports are reviewed by a person, not filtered automatically.
Last updated: July 2026