Version 1.0 · Summary of the policy applied by Rathmar Trading, LLC and its offices in Houston and Zurich. The full policy is provided to counterparties on request.
This policy prevents Rathmar's trading, shipping and payment flows from being used for money laundering, terrorist financing, proliferation financing or tax evasion. It reflects U.S. federal money-laundering law, the Swiss Criminal Code (Article 305bis), the laws of the countries where we trade, and the FATF standards.
Each counterparty is risk-rated on its jurisdiction, ownership, sector, products, trade routes and payment arrangements. The rating sets the depth of due diligence and the frequency of review.
Before trading we verify legal existence and registration; ownership through to ultimate beneficial owners holding 25 percent or more or exercising control; directors and authorized signatories; business activity; bank details; and, where risk requires, source of funds. Counterparties and their owners are screened against sanctions, politically exposed person and adverse-media databases.
Enhanced due diligence applies to politically exposed persons, state-owned entities, counterparties in higher-risk jurisdictions (including those identified by the FATF), complex or opaque ownership structures, and unusual payment arrangements. It requires senior approval.
We watch for pricing out of line with the market, payments from or to unrelated third parties, circular trades, inconsistent or altered documents, misdescribed goods, and routing with no commercial logic.
We do not make or accept cash payments. Payments are made to and received from accounts held in the counterparty's own name, in its country of incorporation or operation. Third-party payments require prior Compliance approval.
Relationships are reviewed periodically according to risk and whenever something material changes. Staff report suspicions to Compliance without alerting the counterparty; Compliance decides whether to report to the authorities.
Due-diligence and transaction records are kept for at least ten years after the relationship ends. Staff are trained on joining and every year after.