03Compliance
Compliance is not an annex: it is the precondition.
The regulatory viability of every transaction is assessed before its commercial viability. This is the framework under which we work and the process we apply to every counterparty.
03.1Regulatory framework
The rules that govern every transaction.
Law on the control of foreign trade in defence materiel and dual-use items. The Spanish framework that regulates intermediation and requires prior authorisation for each transaction.
Regulation on the control of foreign trade in defence materiel, other materiel and dual-use products and technologies, including the Defence Materiel List.
European Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items.
Common EU rules governing the control of exports of military technology and equipment, including the eight assessment criteria.
03.2Registration and authorisations
Verifiable credentials.
Empire Innovation is entered in the Defence Industry Register of the Ministry of Defence (No. 1585, registration in force) and authorised as a defence materiel intermediary in the Special Register of Foreign Trade Operators (REOCE), in accordance with Law 53/2007 and Royal Decree 679/2014.
The complete registry documentation forms part of our verification dossier, available on request.
03.3Due diligence
The process we apply to every counterparty.
Corporate identification and ultimate beneficial ownership
Verification of the counterparty, its authorised representatives and its ultimate beneficial owner (UBO) against official registers.
Sanctions screening
Screening against the United Nations, European Union and OFAC sanctions lists, at the outset and during the transaction.
End-user verification
End-user certificate (EUC) and destination assessment in accordance with the criteria of Common Position 2008/944/CFSP.
Documentary and banking consistency
Correspondence between the contract, invoicing and bank accounts held in the counterparty's name, without exception.
Verification for banks and counterparties.
Corporate dossier, registry documentation and Sanctions and Export Control Policy available on request to qualified parties.