Operating in the Syrian context demands the strictest sanctions and KYC posture. The corridor's onboarding regime is built around full UBO disclosure, multi-regime screening, and continuous monitoring — applied identically to anchors, vendors, and individuals.
The KETURAH Master Entity applies a strictest-of-all-regimes posture: a counterparty is cleared only if it passes screening against every applicable sanctions list — not the lightest one. The same screening is applied to every category of counterparty: sovereign anchors, DFIs, institutional investors, foundations, vendors, advisers, and individuals named in the title chain.
Sanctions failure = onboarding hard stop. A hit on any screened regime is treated as a critical-tier risk (Risk Register R-01, Verification Gate VG-PLAT-05). The decision is binary; there is no scope for commercial override.
Screening is conducted against the live consolidated lists of the following authorities (non-exhaustive; supplemented by additional regimes where the counterparty's jurisdiction requires it):
Office of Foreign Assets Control — Specially Designated Nationals (SDN), Sectoral Sanctions Identifications (SSI), Non-SDN Menu-Based Sanctions, Caesar Act–related designations.
Office of Financial Sanctions Implementation — UK consolidated list under the Sanctions and Anti-Money Laundering Act 2018.
EU consolidated sanctions list, including Council Regulation (EU) No 36/2012 restrictive measures concerning the situation in Syria, with updates as published.
Additional checks: UN Security Council consolidated list; Politically Exposed Persons (PEP) registers; adverse media (recognised compliance databases); and counterparty-jurisdiction–specific lists where applicable.
For each counterparty, screening covers:
The corridor's ultimate-beneficial-owner methodology is built on the FATF UBO definition, hardened for the Syrian context:
Entity name, jurisdiction, contact, intended scope of engagement, and named principals. Submitted via the Request Diligence form.
KETURAH responds with a KYC pack listing the documentation required: corporate registry extract; constitutional documents; UBO chain to natural persons; passports of principals; proofs of address; source-of-funds narrative.
Compliance team runs the entity, principals, and UBOs against OFAC, OFSI, EU, UN, PEP, and adverse-media databases. Documented in a screening file with timestamp and watermark.
Where screening returns no hit, the file proceeds to internal review for credit quality and integrity factors not surfaced by automated screening (jurisdictional residence, source-of-wealth coherence, sectoral exposure).
Cleared counterparties receive notice and execute the mutual NDA. Data-room credentials follow within five business days. Refusal is communicated in writing with a redacted basis where lawful.
Vendors face the same screening, with two additions:
Vendor non-compliance is tracked in the Risk Register as R-10 (critical tier).
A counterparty who is refused onboarding may request a re-review where they believe the screening result is the consequence of a false positive (homonym, outdated record, jurisdictional ambiguity). Re-review is performed by a second compliance officer; where the result holds, the decision is final at this stage. A counterparty can re-apply at any time if the underlying circumstances change.
Cleared counterparties are re-screened:
Sanctions and KYC enquiries are directed via the Request Diligence form with the subject line SANCTIONS/KYC. All correspondence is logged in the compliance file.
This policy is non-negotiable. No anchor, sponsor, or strategic ask overrides the screening result. The discipline is institutional; the corridor's integrity depends on it.