1. Screening#
- Onboarding screening on day one.
- Ongoing screening daily against updated lists.
- Beneficial-owner screening at the ≥25% threshold.
- Adverse-media screening on enhanced due diligence cases.
2. Screening matrix#
| Counterparty | Lists screened | Cadence |
|---|---|---|
| Personal customer | UK OFSI, EU, UN | Onboarding + daily |
| Business customer + UBOs ≥25% | UK OFSI, EU, OFAC, UN, PEP | Onboarding + daily |
| Supplier | UK OFSI, EU, OFAC, UN | Onboarding + monthly |
| Director / officer | UK OFSI, EU, OFAC, UN, PEP | On appointment + daily |
3. OFSI reporting#
Where we identify a designated person, we freeze the relationship and report to the Office of Financial Sanctions Implementation as required.
4. Export control#
We do not export controlled telecoms equipment without an Export Control Joint Unit licence. Standard SIM provisioning is not export-controlled; certain cryptographic devices may be.
5. Review & ownership#
Owner: MLRO. Reviewed annually. Cross-references: AML/KYC Framework.
Version history
| Version | Date | Change |
|---|---|---|
| v1.0 | 22 April 2026 | Initial publication. |
This document is published by Boundless Telecom Ltd and forms part of our public legal posture. It is a living document - we update it as the regulatory environment, our supply chain or our products change. If anything here is unclear or you'd like a counter-signed copy, contact legal@boundless.tel and we'll respond within one working day.