Commodity Settlement -- Complex Jurisdictions -- ADGM -- Compliance-First

Sanctions and Commodity Settlement: LCORE's Compliance Framework in Abu Dhabi

The UAE is a neutral trading hub, but LCORE operates a rigorous FATF-compliant compliance framework — ensuring commodity settlement serves legitimate trade, not sanctions evasion.

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UAE
Not Joined Western Sanctions
FATF
Compliant Feb 2024
No
US Persons in Structure
Case
by Case Review
Compliance Framework

Compliance-first,
not compliance-light

LCORE does not facilitate transactions that violate UAE law, UN Security Council resolutions, or ADGM FSRA requirements. Our compliance framework is strict. Our starting position is refusal unless a transaction can be clearly structured within applicable law.

Important disclaimer: LCORE does not provide legal advice, sanctions advice, or compliance opinions. Nothing on this page constitutes legal advice. Counterparties are solely and entirely responsible for their own compliance determinations and must engage their own qualified legal counsel before initiating any transaction. LCORE reserves the right to decline any transaction at its sole discretion.
What LCORE Will Not Do

Transact with entities on UN Security Council sanctions lists. Transact with entities on the UAE national sanctions list (CBUAE). Engage with counterparties where our compliance team identifies unacceptable risk. Accept gold with unverified origin or broken chain of custody.

UAE Jurisdiction

UAE has not joined the EU, UK, or US sanctions regimes. UAE maintains its own CBUAE sanctions list targeting terrorism and WMD proliferation. UAE is FATF-compliant since February 2024. ADGM operates under English Common Law.

No USD Clearing

LCORE transactions do not pass through the US financial system. No USD correspondent bank routing. No SWIFT USD transfers. This limits -- but does not eliminate -- primary OFAC exposure. Each transaction reviewed individually.

Primary vs secondary sanctions:
what applies to LCORE

Sanctions TypeWho It TargetsLCORE Position
UN Security CouncilAll UN member statesLCORE complies fully
UAE CBUAE SanctionsUAE entities and personsLCORE complies fully
OFAC Primary (US)US persons and entitiesLCORE has no US persons; no USD clearing
OFAC SecondaryNon-US entities transacting with SDNsCase-by-case review; counterparty must advise own counsel
EU/UK SanctionsEU/UK persons and entitiesLCORE is not an EU/UK entity; counterparties advise own counsel
This table is informational only and does not constitute legal advice. Sanctions regimes are complex and change frequently. Counterparties must obtain independent qualified legal advice before proceeding.
FAQ

Frequently asked questions

Does the UAE's non-adoption of Western sanctions mean LCORE ignores them?
No. Although the UAE has not unilaterally adopted all Western (US/EU/UK) sanctions, LCORE as an ADGM-regulated entity applies US OFAC, EU, and UK sanctions screening as part of its compliance framework. This is standard practice for internationally active financial institutions seeking correspondent banking relationships and insurance from Western-regulated providers.
What is enhanced due diligence (EDD) and when does LCORE apply it?
EDD is an elevated level of KYC/AML scrutiny applied to higher-risk clients and transactions — including those involving jurisdictions, industries, or counterparties with elevated sanctions or money laundering risk. LCORE applies EDD to all commodity settlement transactions involving parties from designated higher-risk jurisdictions, regardless of whether a specific sanctions violation is identified.
Can LCORE settle commodities traded between two non-UAE parties using gold in Abu Dhabi?
Yes, subject to both parties clearing LCORE's KYC/AML and sanctions screening. LCORE can act as settlement agent for bilateral commodity trades where neither party is UAE-based, using the Abu Dhabi vault as the neutral gold delivery and title transfer point under ADGM English Common Law.
Who can access LCORE's sanctions commodity settlement services?
Institutional counterparties only: family offices, commodity traders, sovereign entities, mining companies, and corporate treasuries. Minimum $5M. Full KYC/AML/source-of-funds onboarding required before access.
How is sanctions commodity settlement regulated at LCORE?
ADGM (Abu Dhabi Global Market) under FSRA regulatory oversight. English Common Law jurisdiction. LCORE Reg. 28158. Lloyd's of London insurance $250M per shipment. All operations comply with UAE AML/CFT requirements.

Complex jurisdiction. Clean structure.

Confidential initial review. LCORE compliance team. No commitment before review. Institutional only.

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