Global Sanctions Compliance

Our commitment

We conduct global sanctions compliance in line with the laws of Georgia, where we are based, and with the applicable financial and trade sanctions of the United Nations, the United States (administered by OFAC), the European Union and the United Kingdom (OFSI and the FCDO), together with those of other jurisdictions relevant to where a journey goes, who is travelling and who supplies it.

We do not knowingly deal with sanctioned persons, entities or vessels, or arrange anything that would breach, or help anyone get around, sanctions.

Who we screen

For every reservation we screen, before any payment is taken:

• the client and every guest;
• the person or company paying, and the name on each incoming transfer;
• every supplier, and every yacht or vessel by name.

We check these names against the consolidated lists published by OFAC, the United Nations, the European Union and the United Kingdom, which we refresh several times a day. A list that is missing or out of date does not count as clear: the reservation waits until screening is complete.

Identity and due diligence

Sanctions screening works only if we know who we are dealing with. Before payment we verify the passport of the person making the booking and ask who will pay. For larger bookings we ask where the funds come from, and we carry out further checks, including on politically exposed persons and adverse media.

We ask where a client's money comes from once, not on every booking: at member onboarding, or with a client's first larger booking. That declaration is relied on for a year. A booking that departs from it, because someone new is to pay or it goes beyond the year the client described, is asked about on its own, and every payer other than the client is screened each time.

We apply enhanced due diligence to clients and journeys connected with jurisdictions listed by the Financial Action Task Force or under broad sanctions programmes.

Who and where we cannot serve

We do not provide services to anyone subject to sanctions, to persons owned or controlled by them, or to residents of jurisdictions under comprehensive sanctions. We do not arrange travel or payment where that would be prohibited, and we may decline a client, a supplier or a destination because of the risk involved, even where the law would allow it.

What happens if a check needs attention

A reservation may be held while your concierge looks into something, and you may be asked for more information. Many checks clear without any action on your part.

We may decline a reservation or stop arranging one, and the law may prevent us from telling you why. Where the law requires, we will report matters to the authorities or to our bank, and funds may have to be frozen rather than returned. We are not liable for loss caused by a delay or refusal that we reasonably consider necessary for compliance.

What we ask of clients

Please give us complete and accurate details of everyone travelling and everyone paying, and tell us if anything changes. It is a serious breach of our Booking Terms to hide who is travelling or paying, or to use a booking to get around sanctions. If that happens we will end the booking, and we may report it.

What we ask of suppliers

Suppliers must comply with sanctions and must tell us at once if they, their owners or their vessels become subject to any restriction. The details are in our Supplier Code of Conduct.

Records and review

Every decision on a flagged reservation is made by a person and recorded with its reasons. We keep compliance records for five years after a relationship ends, or longer if the law requires, and we review this programme when the rules change, including after each plenary of the Financial Action Task Force.

Raising a concern

If you have a question about this statement, or you believe something connected with us breaches sanctions, write to concierge@example.com. We treat these reports in confidence.