KYC & AML Policy
Blue Ocean Club LLC takes financial crime prevention seriously. Although retail yacht brokers in the United States are not currently designated “financial institutions” under the Bank Secrecy Act, the size of charter transactions and the international nature of our clientele mean we voluntarily apply a risk-based Know-Your-Customer (KYC) and Anti-Money-Laundering (AML) programme aligned with FinCEN guidance, OFAC sanctions, the EU AMLD framework, and FATF recommendations.
1. When KYC is performed
KYC is completed before signing the Charter Agreement and before any funds are wired to the stakeholder account. For repeat clients, KYC is refreshed every 24 months or whenever circumstances materially change.
2. Information collected
For individual Charterers we collect:
- Full legal name, date of birth, residential address, nationality
- A government-issued photo ID (passport preferred)
- Proof of address (utility bill or bank statement, ≤ 3 months old)
- Source-of-funds declaration for the Charter Fee
For corporate Charterers we additionally collect:
- Certificate of incorporation and good-standing certificate
- Registered office and operating address
- Ultimate Beneficial Owner (UBO) identification for any holder of ≥ 25%
- Authorising resolution or power of attorney for the signing officer
3. Sanctions & PEP screening
All Charterers, signatories, and UBOs are screened against the U.S. OFAC SDN list, the EU Consolidated List, UK OFSI, and UN sanctions, plus politically-exposed-person (PEP) and adverse media databases. A positive hit triggers enhanced due diligence and may result in the booking being declined.
4. Source of funds
For charters above USD 100,000 we request documentary evidence of source of funds (recent bank statements, sale-of-asset confirmation, employer letter, audited financials, or equivalent). Cash payments are not accepted under any circumstances.
5. Record keeping
KYC files and transaction records are retained for seven (7) yearsafter the end of the client relationship, stored encrypted at rest, and accessible only to authorised personnel.
6. Reporting suspicious activity
Where the firm has reasonable grounds to suspect that funds derive from criminal activity, terrorism financing, or sanctions evasion, we will decline the booking and, where required by law, file a Suspicious Activity Report (SAR) with FinCEN or the relevant competent authority. Tipping off the client is prohibited.
7. Privacy
All KYC data is processed under our Privacy Policy on the legal bases of contract performance and legal obligation. We do not sell or share KYC data for marketing purposes.