01Lawful purpose and agreed scope
We work on projects with an identifiable lawful business purpose and an agreed scope. We do not accept instructions to disguise a transaction's purpose, conceal relevant participants, falsify records or evade applicable restrictions.
Where legal, tax, financial or other specialist questions arise, we arrange the appropriate independent input and coordinate the agreed work. Advice, representation and specialist decisions remain with the responsible provider under the applicable written terms.
02Proportionate counterparty checks
The extent of our checks depends on the service, counterparties, countries, payment arrangements and other relevant risk factors. We may ask for business registration details, the authority of a representative, relevant ownership or beneficial-owner information and an explanation of the project.
We use appropriate documents and lawful sources to assess the information received. Where circumstances justify further checks, we may request clarification or supporting evidence about the parties, commercial purpose or source of funds involved. We seek information relevant to the identified risk rather than collecting unnecessary documents.
03Sanctions screening
Our review includes applicable US sanctions administered by the Office of Foreign Assets Control and any other sanctions regime that applies to the engagement. It considers relevant counterparties, ownership, locations and the proposed activity.
Screening considers applicable ownership rules as well as listed names. A potential match requires review before a conclusion is reached. We revisit checks when material changes to the project, parties, ownership or applicable restrictions make this necessary.
04Payments and records
Payments to Continental Apex are for our agreed services unless a different lawful arrangement has been separately reviewed and documented. The payer, invoice and commercial purpose must be understandable. Unexplained third-party payments or inconsistent instructions may require additional checks before we proceed.
We retain proportionate records of relevant checks, decisions and supporting information for the periods required by applicable obligations and legitimate business needs. Access is limited to people who need it, and retention is considered alongside our Privacy Notice.
05Concerns and prohibited projects
We may pause work, seek additional information or obtain specialist advice when a material concern arises. We decline or end work that is prohibited or whose material legal or compliance concerns cannot be resolved, subject to applicable law and the engagement terms.
We comply with applicable reporting duties and restrictions on dealing with property or funds. A suspected sanctions issue is reviewed before any action, including a proposed refund or onward payment.
06Responsibility and contact
Company management is responsible for applying and reviewing this policy and for ensuring that relevant concerns are addressed. The approach is reviewed when our services, material risks or applicable requirements change.
For a question or concern relating to an engagement, contact contact@continentalapex.com. Do not send sensitive identity documents unless we have agreed why they are needed and how they should be provided.