Sanctions screening

OFAC · UN · EU · UK screening

All counterparties, sponsors, investors and advisors are screened across four major sanctions lists on a continuous basis. Screening is a prerequisite for engagement on any investment, transaction or advisory mandate.

Qualitative overview only — not legal advice. Seek independent counsel for sanctions compliance obligations.

OFACACTIVE

OFAC SDN & Consolidated List

US Treasury / Office of Foreign Assets Control

Specially Designated Nationals and Blocked Persons, plus Consolidated Sanctions List. Mandatory for any US-nexus transaction or US-person counterparty.

Cadence: Continuous — updated on designation events
Group relevance: Dark Pools LLC (Delaware) is a US-nexus entity. OFAC compliance is mandatory for all counterparties and transactions.

UNSCACTIVE

UN Consolidated Sanctions List

United Nations Security Council

Individuals, groups and entities subject to UN Security Council sanctions measures.

Cadence: Continuous — updated on UNSC resolutions
Group relevance: Applies to all cross-border transactions and counterparties regardless of jurisdiction.

EUACTIVE

EU Financial Sanctions

European Union

EU consolidated list of persons, groups and entities subject to restrictive measures.

Cadence: Continuous — updated via Official Journal of the EU
Group relevance: Relevant for any EU-connected LP, counterparty or correspondent bank relationship.

HMTACTIVE

UK HMT Financial Sanctions

HM Treasury (UK) / OFSI

UK sanctions list maintained post-Brexit under the Sanctions and Anti-Money Laundering Act 2018.

Cadence: Continuous — updated via OFSI
Group relevance: Relevant for UK-connected LPs, advisors and correspondent relationships.

Screening process

Three-point screening perimeter

Screening operates at three points in every engagement: onboarding, transaction initiation and on a rolling periodic basis.

Onboarding

Every new counterparty — investor, sponsor, advisor or contractor — is screened against all four lists before engagement proceeds. A match triggers an enhanced-due-diligence review.

Transaction initiation

Each material transaction triggers a fresh screen. Beneficial ownership is traced to the ultimate beneficial owner (UBO) and screened in full.

Rolling periodic

All active counterparties are re-screened on a periodic basis and immediately on any list update event. The compliance log is maintained by Sable Bridge Capital (Pvt) Ltd and accessible to Dark Pools LLC.

Self-certification

Sanctions self-certification

If you are engaging with the group as an investor, sponsor or advisor, submit a sanctions self-certification here. This is noted in the group compliance log. It does not replace formal KYC/AML screening.

Self-certification is a compliance note only — it does not constitute a legal clearance.

Screening reference only · Seek qualified sanctions counsel · Not legal advice