Purpose and scope
The policy establishes a practical, risk-based process for knowing suppliers, customers, agents, consultants, logistics providers, banks and other counterparties; identifying integrity, sanctions, ownership and human-rights risk; and taking documented decisions before and during a relationship.
Baseline due diligence
Blue Palm verifies legal identity, registration, addresses, authorised signatories, direct and ultimate beneficial ownership, bank details, relevant licences and certifications, sanctions exposure, reputation, commercial rationale, payment terms and proposed subcontractors.
Enhanced due diligence
Additional review is required where there is public-sector or PEP exposure, use of intermediaries or success fees, conflict-affected routes, opaque ownership, unusual payment instructions, adverse allegations or indicators of bribery, fraud, forced labour, child labour, trafficking or sanctions evasion.
Risk tiers and review
Standard relationships are refreshed at least every three years; elevated relationships at least every two years; high-risk relationships at least annually and before material transactions. Prohibited or unresolved relationships must not be onboarded, paid or transacted with.
Sanctions compliance
At minimum, Blue Palm screens relevant parties against the UN Consolidated List and, for UAE activities, the UAE Local Terrorist List and applicable implementation requirements. Other EU, UK, US or relevant lists are checked when required by law, contract, bank, insurer, currency, goods, route or risk assessment.
Stop and escalate
A possible sanctions match or prohibited activity requires an immediate documented hold. Personnel must not release goods, make or return payments, tip off the affected party or restructure the transaction to avoid a restriction. Compliance verifies the match and obtains specialist advice where needed.
Contracts, payments and reporting
Written contracts must describe the real goods or services and include relevant compliance, audit and termination controls. Payments require verified delivery, valid invoices and verified bank details. Red flags must be stopped and reported; good-faith reporters are protected.
Legal & standards reference
This is a concise website presentation of the legal and standards references contained in the supplied policy. The official text, local legal advice and applicable entity or licence conditions should be checked before relying on a provision.
| Instrument | Relevance |
|---|---|
| Iraq Anti-Money Laundering and Counter-Terrorist Financing Law No. 39 of 2015 | Supports risk-based integrity controls in Iraq. |
| UAE Cabinet Decision No. 74 of 2020 | Basis for UAE targeted financial sanctions implementation and UN/UAE list screening. |
| UAE Federal Decree-Law No. 31 of 2021, as amended | Relevant to bribery, fraud and criminal integrity risk. |