Alpha Green Ltd
Master Governance & Regulatory Framework AML
1. Governance Philosophy
Alpha Green Ltd operates under a disciplined governance model designed to ensure:
Regulatory compliance
Commercial integrity
Risk-managed brokerage conduct
Institutional accountability
Ethical independence
The Company maintains structured internal oversight proportionate to the scale and nature of its brokerage and advisory activities.
Alpha Green Ltd operates strictly in a non-operational brokerage and advisory capacity.
2. Regulatory Compliance Framework
Alpha Green Ltd conducts its activities in accordance with applicable:
UK Anti-Money Laundering Regulations
Proceeds of Crime Act 2002
UK Sanctions and Anti-Money Laundering Act 2018
EU restrictive measures (where applicable)
International sanctions regimes, including OFAC principles where relevant
Where transactions involve cross-border counterparties, compliance review considers applicable multi-jurisdictional exposure.
3. Risk-Based Compliance Approach
The Company applies a proportionate, risk-based methodology across all engagements.
Compliance review may include:
Counterparty due diligence
Sanctions screening
Transactional risk profiling
Jurisdictional exposure assessment
Vessel and trade evaluation
Corporate ownership analysis
Risk categorisation determines the depth of review and ongoing monitoring.
4. Know Your Client (KYC) & Due Diligence
Where appropriate, Alpha Green Ltd may request:
Government-issued identification
Corporate incorporation documentation
Ownership and control structure disclosure
Ultimate Beneficial Owner (UBO) identification
Source of funds verification
Failure to provide required compliance documentation may result in refusal, suspension, or termination of services.
The Company reserves discretion to decline mandates that present disproportionate compliance exposure.
5. Sanctions & Trade Controls
Alpha Green Ltd does not knowingly engage in transactions involving:
Sanctioned individuals
Sanctioned entities
Sanctioned vessels
Prohibited jurisdictions under applicable UK or EU regulations
All proposed transactions may be subject to sanctions screening prior to confirmation or fixture.
Where red flags arise, engagements may be paused or declined pending further review.
6. Reporting & Regulatory Cooperation
Where legally required, Alpha Green Ltd may:
Submit Suspicious Activity Reports (SARs)
Suspend or decline transactions
Disclose relevant information to competent authorities
Cooperate with law enforcement or regulatory bodies
Such actions may occur without prior notification where disclosure is legally restricted.
7. Anti-Bribery & Ethical Standards
Alpha Green Ltd maintains:
Zero tolerance for bribery or corruption
Compliance with the UK Bribery Act 2010
Professional independence in brokerage negotiations
Transparent commercial conduct
Conflict awareness and management procedures
No facilitation payments or improper inducements are permitted.
8. Data Protection & Confidentiality
The Company processes personal data in accordance with:
UK GDPR
EU GDPR (where applicable)
UK Data Protection Act 2018
Internal safeguards include:
Encrypted communications
Controlled access protocols
Confidential handling of commercial information
Restricted internal data exposure
Brokerage information is treated as commercially sensitive.
9. Operational Limitation of Role
Alpha Green Ltd acts strictly as:
A maritime broker
A commercial intermediary
An advisory representative
The Company does not:
Own vessels
Operate vessels
Manage vessel operations
Control cargo movement
Provide legal or financial advice unless separately contracted
Operational compliance obligations of shipowners, charterers, traders, and counterparties remain their independent responsibility.
10. Oversight & Internal Review
Compliance processes are periodically reviewed to ensure:
Alignment with evolving UK regulatory standards
Proportionate risk management
Continued institutional discipline
Policies may be updated to reflect regulatory developments or changes in market exposure.
Institutional Positioning Statement
Alpha Green Ltd operates within the international maritime trade environment under a structured governance framework aligned with London commercial standards.
The Company’s compliance model is designed to safeguard:
Commercial counterparties
Market integrity
Regulatory alignment
Long-term professional credibility