Legal

AML, Sanctions, Export & Anti-Bribery Policy

Version 1.0 · Last updated: 21 July 2026

ColdMatch Group operates a zero-tolerance approach to money laundering, terrorist financing, sanctions evasion, export-control violations and corruption. This policy applies to all users, suppliers, financing partners and personnel.

1. Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF)

ColdMatch Group is not itself an obliged financial institution but supports the AML/CTF efforts of the financing partners with whom users interact.
Users must provide accurate identity, ownership and source-of-funds information when requested for onboarding or financing evaluation.
We may review transactions, RFQs and account activity and may request documentation (company registration, beneficial ownership, proof of address, source of funds, contracts) where appropriate.
We reserve the right to reject, freeze, suspend or terminate accounts that we reasonably suspect are involved in money laundering, terrorist financing or proliferation financing, and to report such activity to competent authorities to the extent permitted or required by applicable law.

2. International sanctions

Use of the platform must comply with all applicable sanctions regimes, including those of the European Union, the United Nations, the United Kingdom, the United States (OFAC) and other applicable jurisdictions. Users may not use the platform if they, their controllers, ultimate beneficial owners, counterparties or intended end-users are the target of comprehensive sanctions or are located in comprehensively sanctioned territories.

3. Export control & dual-use

Certain refrigeration equipment, refrigerants, control systems, ammonia/CO₂ systems or components may be subject to export controls, dual-use restrictions or environmental (F-gas / ozone-depleting substance) regulations. Buyers and suppliers are solely responsible for obtaining all required licences, authorisations and end-use / end-user certifications prior to shipment.

4. Anti-bribery & anti-corruption

ColdMatch Group prohibits any form of bribery, kickback, facilitation payment or undue advantage, whether offered to or received from public officials or private parties.
Users and suppliers must comply with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), applicable EU legislation and equivalent laws in every relevant jurisdiction.

5. Fraud prevention

We operate risk controls to detect and prevent fake companies, identity theft, false technical information, counterfeit equipment and marketplace abuse. Confirmed fraudulent activity results in immediate termination and, where appropriate, reporting to competent authorities.

6. Reporting concerns

Compliance or ethics concerns can be reported confidentially to legal@coldmatchgroup.com. We will not retaliate against any user or supplier for reporting a concern in good faith.

7. Reservation of rights

Nothing in this policy limits any right, remedy or authority reserved by ColdMatch Group under its Terms of Service, Acceptable Use Policy or applicable law. All rights not expressly granted are reserved.