Market access, sanctions and customer eligibility

1. Current demonstration controls

This protected site accepts only simulated orders. Market-policy version 2026-09-15-demo-v1 permits the countries listed below, excluding California in the United States. Other locations are unavailable under the demo’s commercial market-access policy; this does not mean every excluded country or person is subject to sanctions.

Supported locations: Austria, Australia, Belgium, Bulgaria, Canada, Switzerland, Cyprus, Czechia, Germany, Denmark, Estonia, Spain, Finland, France, United Kingdom, Greece, Croatia, Hungary, Ireland, Iceland, Italy, Japan, Liechtenstein, Lithuania, Luxembourg, Latvia, Malta, Netherlands, Norway, New Zealand, Poland, Portugal, Romania, Sweden, Singapore, Slovenia, Slovakia and United States (excluding California).

Buyer and beneficiary country/state and supplied order addresses are checked. The demo does not independently establish residence, incorporation, beneficial ownership, bank location or subnational territorial exposure. Passing checkout is not clearance for a real transaction.

2. Applicable law and policy restrictions

For an Irish seller, relevant EU sanctions and Irish implementing/enforcement requirements must be assessed, including UN measures implemented through EU law. UK, US and other rules may also matter where the parties, persons, services, payment route or transaction create the relevant connection. Commercial bank or registry restrictions may be broader than the law.

There is no universal sanctions list or single country test that decides every transaction. The applicable regulation, designations, sectoral restrictions, services prohibitions, territorial measures and any licence must be checked at the time of a proposed live transaction. A bank accepting payment does not establish that FEG may fulfil it.

3. Persons and transactions that must not proceed

• A transaction prohibited by applicable sanctions, including making funds or economic resources available directly or indirectly to a restricted person where prohibited.
• A counterparty owned or controlled by a restricted person where the applicable regime extends restrictions to that entity, whether or not the entity is separately named on a list.
• A prohibited territorial, sectoral, service or end-use connection, including a relevant restricted subnational territory that a country selector cannot resolve.
• An attempt to conceal the buyer, beneficiary, source or destination of funds, ownership/control or end use, or to evade restrictions through a nominee, intermediary, false address, split order or alternative payment route.

4. Ownership and control require separate analysis

Identify relevant direct and indirect owners and controllers rather than relying only on the customer’s trading name. EU, UK and US ownership/control tests are not interchangeable. Where OFAC blocking rules apply, an entity owned 50% or more in aggregate, directly or indirectly, by one or more blocked persons may itself be blocked even if unnamed. That threshold must not be used as a universal safe harbour under other regimes.

Unclear ownership, inconsistent records or unexplained third-party payments require escalation. A self-declaration, clean name search or favourable country code does not resolve those issues.

5. Proposed checks before a live sale

Before accepting a live order, the proposed process requires identifying the contracting entity, purchaser’s authority, intended beneficiary, relevant ownership/control, business purpose, payment route and relevant locations. Collect only proportionate supporting evidence and handle it under an approved privacy and retention policy.

Screen relevant parties using current official designations and applicable restrictions; assess possible matches with identifiers, not names alone. Reassess material changes and check again before payment acceptance where relevant, transfer or retirement. This demonstration has no live screening-provider integration and must not be represented as having completed these checks.

6. Review holds, refusal and lawful release

A possible match or unresolved restriction must put a proposed live transaction on hold. An authorised FEG reviewer, with specialist advice where needed, must document the applicable rule, evidence, decision and any licence before release. A salesperson or customer cannot override a legal restriction. FEG has not yet designated the accountable live-service reviewer in this demo.

Where legally permitted, explain whether the issue is missing information, a commercial availability rule or a legal restriction and how to request correction. Do not promise a refund where a freeze or other prohibition prevents movement of funds. Any freezing, reporting, recordkeeping or return of funds must follow the applicable law and competent-authority requirements.

7. California and AB 1305

California checkout is unavailable while FEG reviews the offering and associated disclosures. California is not a sanctioned jurisdiction. The restriction is a precautionary product/claims policy, not a statement that selling SAF attributes there is inherently unlawful.

Section 44475 concerns marketing or selling products falling within the statutory voluntary-carbon-offset definition in California. Describing an instrument as SAF attributes or book and claim does not, by itself, decide classification; the substance and marketing claims matter.

Sections 44475.1 and 44475.2 address specified offset-use and environmental claims, with their own California connections and exclusions. Blocking a billing address does not establish that marketing or company/product claims fall outside those provisions. The disclosure page and claims guide must be considered alongside the actual evidence and intended audience.

8. Claims, disclosures and separate reporting duties

No customer may use this demonstration as evidence of an achieved reduction, offset, carbon-neutral outcome or net-zero result. For a live product, approved claims must match the specific methodology, calculation, allocation and retirement evidence, with verification limitations stated.

A disclosure should distinguish the seller’s product evidence, the purchaser’s use of attributes and the company’s own emissions/target claims. Supplier links should identify the source and verification status; a link or disclaimer does not discharge an applicable duty to provide accurate information. SB 253 and SB 261 concern separate corporate reporting questions and should not be conflated with AB 1305 or treated as a certificate-eligibility test.

9. Corrections, records and policy changes

If a restriction appears to apply incorrectly, contact FEG through the link below with the country/state, affected page and relevant non-sensitive context. Do not email identity documents or bank details until an appropriate secure route is agreed. Review is not a guarantee of acceptance.

For live trading, FEG must retain the policy version, screening evidence, reasons, reviewer and release/refusal decision under a defined lawful retention schedule. Official measures change; this draft does not claim continuous monitoring or a legally approved country list. Updates to legal restrictions apply as required by law; changes to commercial terms must follow the accepted agreement.