1. Purpose and Status
1.1This Statement describes how ClearCorridor Technology (Pty) Ltd (“ClearCorridor”) screens the entities admitted to its platform, and the disclosed natural persons behind them, against sanctions, criminal and related watchlist data. It is published so that any participant relying on platform participation as part of its own due diligence can assess the screening process for itself and decide whether it is sufficient for that participant’s own purposes.
1.2What ClearCorridor stands behind. ClearCorridor warrants that it operates the screening process described here with integrity: it does what this Statement says it does, consistently, and keeps an auditable record of having done so. ClearCorridor does not warrant that its screening is sufficient to discharge any other party’s own legal or regulatory obligations. Each participant retains its own responsibility for the due diligence the law requires of it, and must form its own view of whether this process meets that responsibility.
1.3Screening is one control among several. It does not assess, and is not a representation about, any counterparty’s commercial integrity, solvency, operational reliability or suitability for a particular cargo, lane or load.
2. Standard
2.1The screening process is designed to give effect to the customer-screening expectations of the Financial Action Task Force (FATF) Recommendations as a minimum standard, applied consistently across all jurisdictions in which platform participants are admitted.
2.2Personal information processed for screening is handled in accordance with the Protection of Personal Information Act 4 of 2013 and the ClearCorridor Privacy Notice (CCA-PRIV-001), including the basis on which any consequential determination is made and the cross-border-transfer basis recorded there.
3. Who Is Screened
3.1ClearCorridor screens each admitted entity, whether a Cargo Principal or a Carrier, together with its directors, its beneficial owners, and, where the entity is a trust or has a trust in its ownership chain, its trustees, in each case as disclosed by the entity at admission.
3.2Each entity warrants the truth, accuracy and completeness of the persons it discloses, and undertakes to notify ClearCorridor of any change to its directors, beneficial ownership or control. The integrity of screening depends on the accuracy of what is disclosed.
4. What They Are Screened Against
4.1Disclosed entities and persons are screened against the consolidated sanctions, criminal-and-enforcement and politically-exposed-person datasets maintained by OpenSanctions, ClearCorridor’s screening data provider, drawn from official and recognised public sources and refreshed by that provider on an ongoing basis.
4.2A potential match in a sanctions, criminal or otherwise unresolved high-risk category is treated as a gating matter that holds the relevant account pending resolution (sections 6 and 7). Jurisdictional and similar contextual data points are treated as informational only and do not, of themselves, gate an account.
4.3Politically-exposed-person status. Screening covers politically-exposed-person status. PEP status is not, of itself, an adverse finding and does not bar participation; where it arises it is assessed and managed internally by ClearCorridor as part of its own enhanced due diligence. ClearCorridor does not represent the PEP status of any individual counterparty to any other participant.
5. When Screening Occurs
5.1Each entity and its disclosed persons are screened: (a) at admission, as a condition of activation; (b) on any disclosed change to the entity’s directors, beneficial ownership, control or structure; and (c) on a recurring monthly cycle thereafter, for as long as the account remains on the platform.
6. How Potential Matches Are Assessed
6.1Disclosed names and identifiers are matched against the datasets using OpenSanctions’ recommended matching algorithm and scoring configuration for screening, as set out in OpenSanctions’ published matching and scoring guidance, calibrated to favour confirmed matches over noise, with any further tuning we apply reviewed by us periodically.
6.2A potential match is not, of itself, a finding. Where screening returns a potential match in a gating category, the account is held under section 7 while we assess the match and record a disposition; no such match has any consequence for the account until we have done so. Where we assess a match and record it as not a true match, it is set aside and is not raised again on later screens of the same person.
7. Fail-Closed Control
7.1While a screen is pending, or has returned a result that has not yet been resolved, the platform withholds the account’s transacting functions until a clear result is returned. For a Carrier, this means the ability to bid and to be engaged; for a Cargo Principal, it means activation, the posting of Cargo Movement Requests and the issuance of Carrier Engagement Confirmations.
7.2This is a platform-integrity control, not an adverse finding about any participant, and ClearCorridor accepts no liability for any delay attributable to it.
8. Outcomes and Their Effect
8.1Screening resolves to one of the following states, each recorded against the account:
(a) Clear: no adverse match in any gating category.
(b) Under review: a potential gating match is held pending our assessment; transacting functions remain withheld under section 7.
(c) Adverse (confirmed): a gating match confirmed on assessment. The account is placed in the status Suspended — Compliance pending resolution, and ClearCorridor may notify affected counterparties of the suspension.
8.2Reinstatement following a compliance suspension follows resolution of the underlying cause and is at ClearCorridor’s sole and unfettered discretion.
8.3Interface labels. Where a counterparty’s screening status is shown to you in the platform, it appears under one of the following labels, each mapping to a state above: Screened ยท no adverse match (a Clear result, 8.1(a)); Screening under review (a potential gating match held pending our assessment, 8.1(b)); Screening in progress (a screen is running or pending and transacting functions are withheld under section 7); and Not yet screened (no screen has yet completed for that counterparty). A counterparty whose screening is unresolved, or whose result is adverse, does not become available to transact with.
9. What You May, and May Not, Rely On
9.1You may rely on the fact that, for any entity shown as an active participant, ClearCorridor has applied the process described in this Statement and holds a record of having done so.
9.2You may not treat that fact as discharging your own screening, sanctions or customer-due-diligence obligations. You must form your own assessment of whether the process described in this Statement is sufficient for your purposes, and you retain your own responsibility for that assessment. ClearCorridor warrants that it performs this process; it does not warrant that the process satisfies your obligations.
9.3Consistent with the Platform Agreements, the outputs of screening and scoring are produced on the information available to the platform at the relevant time and are not a warranty, recommendation or assurance of any counterparty’s integrity, performance, solvency or suitability.
10. Record and Audit
10.1Each screen is recorded in an append-only platform log: the provider used, the date, the outcome, and the disposition recorded. This record supports ClearCorridor’s own audit obligations and can substantiate, on request and as the platform provides, that the process in this Statement was applied to a given counterparty at a given time.
11. Changes and Version
11.1ClearCorridor may update this Statement as its process, providers or the applicable standards develop. The version current at the time you rely on it is the version that governs that reliance. Material changes are notified through the platform.