Our approach to sanctions screening, asset-freezing obligations, and restricted-party controls.
Comfi Trading FZCO maintains a Targeted Financial Sanctions Policy designed to prevent the company from dealing, directly or indirectly, with sanctioned individuals, entities, groups, organisations, or restricted parties.
As part of its AML/CFT compliance framework, Comfi applies sanctions screening controls before onboarding new customers, during ongoing customer reviews, and in connection with relevant transactions and counterparties. These controls support compliance with applicable sanctions obligations, including United Nations sanctions, the UAE Local Terrorist List, and other relevant sanctions frameworks.
Comfi’s sanctions compliance approach includes:
- screening customers, counterparties, beneficial owners, authorised representatives, and related parties;
- reviewing existing customer databases against updated sanctions lists;
- screening parties to transactions before execution;
- assessing potential and confirmed name matches;
- escalating sanctions alerts to the Compliance Officer;
- suspending or rejecting transactions where required;
- freezing funds or assets without delay where a confirmed match is identified;
- reporting relevant matches through the appropriate regulatory channels;
- maintaining records of sanctions screening, review decisions, and actions taken;
- prohibiting employees from informing customers or third parties about freezing measures or related compliance actions.
Comfi recognises that targeted financial sanctions are intended to prevent funds, assets, goods, or services from being made available to designated persons or entities. The company therefore applies internal controls to identify sanctions exposure and to ensure that appropriate measures are taken where a match or potential match is detected.
The policy also addresses proliferation financing risks, including risks linked to the financing of weapons of mass destruction, dual-use goods, and sanctions evasion. Comfi applies a risk-based approach to high-risk jurisdictions, restricted parties, complex ownership structures, and transactions that may involve unusual routing, unclear business rationale, or possible circumvention of sanctions controls.
Where a sanctions concern arises, Comfi follows internal escalation and review procedures. The Compliance Officer assesses the alert, verifies available information, determines whether the match is false, partial, or confirmed, and takes the appropriate action in line with applicable requirements.
Through its Targeted Financial Sanctions Policy, Comfi Trading FZCO reinforces its commitment to responsible precious metals trading, sanctions compliance, financial crime prevention, and the protection of the integrity of the market.