Compliance

Everything is checked before anything is signed.

We do not onboard any company, and we do not release any money against any piece of equipment, until we have checked four things. We check the company itself, we check the people who own it, we check the equipment, and we check where the money is coming from. Now and then this will cost us a deal, and we have accepted that, because skipping one of these steps would cost us a great deal more in the long run. Up to now a registry extract, a liveness check and a search of the pledge registers have been enough to settle every case that has come to us.

The counterparty

This applies to lessees, to sellers, to lessors, and when we take on a portfolio it applies to every party in that portfolio. We do not issue a quotation until this part of the file is complete.

Trade licence or registry extract and certificate of good standing, no older than three months
Beneficial owners holding 25 % or more, with a passport copy and an address document for every one of them
Directors and signatories confirmed against the corporate documents
The company and its owners run against the UN, UAE, OFAC, EU and UK sanctions lists, politically-exposed-person databases and negative press
Origin of the first payment and the commercial reason for the transaction

The equipment

This applies to every unit that we buy, to every leaseback, and to every machine that we take over from another lessor or lender.

Evidence of ownership: invoices or purchase agreements, vendor records, any earlier lease or finance contract
Search for pledges and liens in the Emirates Movable Collateral Registry (EMCR) and in registers abroad
Inventory by serial number reconciled with the documents
Physical inspection with photographs before any payment
Export-control and sanctions review for GPU and high-performance compute

The transaction

This applies to every payment, whether it is coming in or going out, for the whole life of the contract.

Each transfer is matched to a schedule, an invoice or a settlement agreement
Accounts in the counterparty's own name only, in both directions
Cash, crypto-assets and third-party payers are refused
The file stays under watch until the contract ends and is refreshed whenever there is a renewal, an assignment or a change of control
Records retained for the period UAE law requires

Onboarding

Five steps to the first payment

In most cases the process takes between two and five working days. The documents we ask for are the same ones any bank or lender would ask for, and we only ask for them once.

Request

You send us the equipment list or the contract, together with the name of the counterparty and the country it is registered in.

Documents

You send us the corporate documents, identification for the owners, and whatever documents prove who owns the equipment.

Screening

We run the company and its owners through the sanctions lists, the politically exposed persons databases and the adverse media checks, and we search the pledge registers for the equipment.

Approval

The file is signed off internally and we send you a quotation with the structure that has been approved.

Contract and payment

The agreement is signed, the bank details are confirmed, and the first payment is made to, or received from, a bank account held in the name of the company.

Enhanced due diligence

When a standard file does not settle it

There are situations where the standard checks are not enough on their own. A large transaction, a counterparty spread across more than one country, an ownership structure with several layers to it, equipment that is being held by a third party, or simply a standard check that has left us with a question. In any of these situations we do additional work, and most portfolio transactions end up in this category.

Recorded video call

The owners and the signatories join a recorded video call with us, in which they confirm who they are, explain what the company does and describe the transaction in their own words.

Inspection on site

One of our engineers visits the data centre or the warehouse where the equipment is held. He records the serial numbers, powers the units on, photographs them, checks them for damage, and obtains written confirmation from whoever is actually in control of the equipment.

Bank and vendor confirmation

We telephone the bank to confirm the account, using a number that we have found ourselves rather than one that was given to us. Where there is any doubt about who owns the equipment, we ask the original vendor to confirm it.

Independent valuation

Before any money is released, we obtain a second opinion on the value of the equipment from an independent appraiser or broker.

Ownership traced to a person

Where the ownership runs through holding companies, nominees or trusts, we work through each layer in turn until we arrive at a living person. We do not make exceptions to this.

Legal opinion

We ask local counsel in the relevant country to confirm which documents prove ownership there, and how enforcement and release of the equipment would work in practice.

Documents

What will be requested

If you are able to send these documents together with your first request, the quotation will come back to you more quickly.

Company

Trade licence or registry extract, no older than three months
Memorandum and articles of association
Shareholder register and declaration of beneficial owners
Passport copy and address document for every owner at 25 % or more and for every signatory
Latest annual accounts or management figures
A bank letter or statement in the company's name

Equipment (purchase or leaseback)

Inventory by serial number
Purchase invoices or delivery notes
Any existing lease, loan or pledge agreement
Confirmation from the data centre or custodian holding the hardware
Photographs, or access for an inspection

Tools

What performs the screening

The automated screening is carried out by specialist providers and runs continuously. The results, however, are always reviewed by a person, and every decision is taken by a person. What a counterparty tells us about itself is never, on its own, sufficient.

Identity and company verification

The owners and signatories go through document, selfie and liveness checks, and the companies themselves are verified against the official registries in their country.

Sanctions, PEP and media

We screen against the UN, UAE, OFAC, EU and UK sanctions lists, the politically exposed persons databases and adverse media, both at onboarding and then again on an ongoing basis for as long as the contract is running.

Pledge and lien searches

We search the Emirates Movable Collateral Registry (EMCR), the UCC filings in the United States, and the national pledge registers of whichever country the counterparty or the equipment is located in.

Begin

Attach the documents to your request and the quotation arrives sooner.

Request terms