Sanctions screening for copper traders: a practical start

Copper moves through many hands and many countries, which makes sanctions a real risk. Banks will stop a payment, freeze funds or close accounts if a sanctioned person is involved anywhere in a transaction. This guide is a practical starting point, not legal advice.

Who to screen

Not just the person you are talking to. Screen:

• the buyer and the seller companies
• their directors and their owners, including the people who ultimately own them
• every intermediary who will be paid
• banks, where you can, and the vessel and shipping company if goods go by sea
• the producer, if you buy at the mine or the plant

Which lists

At a minimum, check the main consolidated lists:

• the UK sanctions list (published by the UK government)
• the US Treasury OFAC Specially Designated Nationals (SDN) list
• the EU consolidated financial sanctions list
• the UN Security Council consolidated list

Your bank may apply more lists than these, and its view is the one that decides whether your payment goes through.

Ownership catches people out

A company does not need to be named on a list to be caught. Under US rules, a company owned 50% or more by sanctioned persons is treated as sanctioned. The UK and the EU apply their own ownership and control tests. That is why you need to know who owns your counterparty, not just its name.

Countries

Some countries are under broad sanctions programmes, and dealing with them is restricted or prohibited regardless of who the counterparty is. Others have targeted sanctions on specific people and companies, including in the mining sector. Check the current position before you trade; it changes.

Keep a record

Save what you checked, when, and what you found. If a bank asks, a dated record of your screening is what protects you.

How Copper Supply helps

Identity (L1) and company (L2) verification include a sanctions check on the member and the company. Our due-diligence reports go further: directors, owners and adverse media on a named counterparty. Members also agree not to use the platform for anyone who is sanctioned.