Compliance is not
optional.
Every transaction we undertake is subject to institutional-grade compliance procedures — before, during, and after execution.
Sanctions Compliance
Sterling Capital Growth screens all counterparties, beneficial owners, vessels, ports, and jurisdictions against current consolidated sanctions lists prior to any transaction commitment.
Our compliance procedures are powered by Sterling Quantum — a real-time sanctions intelligence platform that maintains continuous monitoring against all major sanctions regimes.
OFAC
US Office of Foreign Assets Control
EU Sanctions
European Union Consolidated List
UN Sanctions
United Nations Security Council
OFSI / UK
Office of Financial Sanctions Implementation
KYC Requirements
All new counterparties are required to complete our standard KYC onboarding before any transaction proceeds.
Corporate Entities
- —Certificate of Incorporation / Registration
- —Articles of Association / Bylaws
- —Certificate of Good Standing (within 6 months)
- —Board Resolution authorising signatory
- —Register of Directors and Beneficial Owners
- —Proof of registered address
- —Bank reference letter
- —Two years' audited financial statements
Individual Principals & UBOs
- —Government-issued photo ID (passport preferred)
- —Proof of residential address (within 3 months)
- —Source of funds declaration
- —PEP screening declaration
- —Sanctions self-declaration
Operational Documentation
- —Proof of trading history in relevant commodity
- —Evidence of storage / logistics capability
- —Trade references from prior counterparties
- —Bank details and authorised signatories
- —Insurance certificates where applicable
Submit KYC Documentation
To initiate the onboarding process, contact us with your documentation package or request our standard KYC questionnaire.
AML Policy
Sterling Capital Growth maintains a zero-tolerance policy on money laundering, terrorist financing, and proliferation financing. Our AML programme is reviewed and updated annually in line with FATF guidance and applicable US and international standards.
All employees and agents involved in transaction execution are trained on AML obligations. Unusual transaction patterns, structuring red flags, and counterparty behaviour inconsistent with stated business purposes are reported through our internal escalation process.
Suspicious activity reports are filed with the appropriate authority where required by law.
Modern Slavery Act Statement
This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015. Sterling Capital Growth LLC is committed to ensuring that slavery and human trafficking have no place in our business or supply chains.
We conduct due diligence on all counterparties in our supply chain and require confirmation that they operate with appropriate labour standards. Any indication of forced labour, trafficking, or child labour will result in immediate termination of the counterparty relationship and reporting to authorities.
This statement is reviewed annually and approved by company leadership.
Suspicious Activity Reporting
If you have identified or suspect suspicious financial activity, money laundering, sanctions evasion, or fraud in connection with Sterling Capital Growth or any of its counterparties, you are encouraged to report it. All reports are treated confidentially and reviewed by our compliance team.
Submit a Report →