1. Purpose and scope
Commodity trade can be misused to move illicit funds or to deal with sanctioned parties. This policy sets out how TACJR Participações Ltda. (“Veracana”) prevents that. It applies to all buyers, suppliers, agents, logistics providers and banks we deal with, and to everyone working for Veracana.
It reflects Brazilian Law nº 9.613/1998 (anti-money laundering) and the international sanctions regimes relevant to our trade.
2. Know your counterparty
Before any offer becomes a contract, we identify and verify every counterparty. We:
- verify company registration, legal form and status in the official registry of its country;
- identify the ultimate beneficial owners (individuals owning or controlling 25% or more, or otherwise exercising control) and the authorised signatories;
- confirm the nature of the business and that the transaction makes commercial sense for the counterparty;
- check the source of payment: payment must come from the contracting company, through the banking instrument named in the contract;
- obtain bank references where appropriate.
We do not deal with anonymous parties, shell companies with no verifiable activity, or intermediaries who refuse to identify their principal.
3. Sanctions screening
We screen counterparties, their beneficial owners, vessels and banks against:
- United Nations Security Council sanctions lists;
- U.S. OFAC lists;
- European Union and United Kingdom consolidated lists;
- the sanctions and integrity registers Brazilian law requires, such as CEIS and CNEP.
Screening happens at onboarding, before each contract and when lists change.
We do not trade with sanctioned persons or entities, or with comprehensively sanctioned countries and territories. We do not route cargo or payments to evade sanctions.
4. Red flags
Transactions are stopped and reviewed if, for example:
- the counterparty refuses to provide identification or ownership information;
- payment is offered from a third party, in cash or through an unusual jurisdiction;
- prices, volumes or routing make no commercial sense;
- documents appear altered or inconsistent;
- the counterparty asks for advance fees, “proof of funds” before a contract, or other features typical of commodity fraud.
5. Records
We keep due-diligence and transaction records for at least five years after the end of the relationship, or longer where the law requires.
6. Reporting and consequences
Employees report concerns to compliance at quotes@veracanatrades.com without fear of retaliation. Where the law requires, we report suspicious transactions to the competent authorities. Breaches of this policy lead to termination of the relationship and, for employees, disciplinary action.
7. Review
This policy is reviewed at least once a year.