Compliance

How we work

High-value goods and high-profile clients need a clean paper trail. What cannot be documented, we do not do.

IKnow your customer

Identification of clients and suppliers, including beneficial owners, before a written offer.
Company register extracts and identity documents are requested and kept on file.

Clients, suppliers, partners, goods, countries and routes are screened against the sanctions lists of the EU, the UN and the USA.
Sources: EU Sanctions Map, UN Security Council Consolidated List, OFAC Sanctions List Search.

Supply-chain due diligence based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
For tin, tantalum, tungsten and gold the EU Conflict Minerals Regulation (EU) 2017/821 applies.
Independent inspection, assay or laboratory reports before payment.

Rough diamonds only with a Kimberley Process certificate, as required in the EU by Regulation (EC) 2368/2002.
Polished diamonds and coloured gemstones with reports from independent gemmological laboratories.

We work in line with the German Money Laundering Act (Geldwäschegesetz, GwG).
No cash transactions. Discretion towards third parties never means anonymity towards the law.
Documents are kept for five years.
Payment for goods never passes through Raritas Sourcing: it goes directly to the supplier or via escrow or a notary. Our fee is invoiced separately.

Goods and destinations are checked against the EU Dual-Use Regulation (EU) 2021/821 and German foreign trade law (AWG/AWV).
Where a licence is required, it is obtained from the Federal Office for Economic Affairs and Export Control (BAFA) before shipment. Without a licence, we do not ship.

Exports and imports are declared to customs through licensed customs brokers.
Gold bullion and gold coins count as cash under the EU Cash Controls Regulation (EU) 2018/1672: when our courier carries € 10,000 or more across the external border of the EU, it is declared.
Works of art and antiques travel only with the export and import documents required by EU law and the German Cultural Property Protection Act (KGSG).

Private aircraft are chartered only from operators holding a valid air operator certificate (AOC). Raritas Sourcing acts as organiser and does not operate aircraft.
Chauffeur services are provided by licensed passenger transport companies; security services only by companies licensed in the country of operation. Raritas Sourcing provides neither itself.
Licences and insurance of every partner are checked before work starts; the partners for your mandate are named in the written offer.
The owner of Raritas Sourcing is an investor in one of our partner companies. Clients are always free to choose another licensed partner.