Governance & Legal

Compliance Framework

OCRE operates under a comprehensive compliance framework designed to meet the highest standards of U.S. financial regulation, OFAC sanctions enforcement, and international trade law.

Regulatory Architecture

OCRE is structured as a B2B OTC Physical Clearing Network exclusively serving Eligible Contract Participants (ECPs). Our compliance infrastructure is designed from the ground up to ensure that every transaction, counterparty, and material movement meets or exceeds U.S. regulatory requirements — including OFAC sanctions, Bank Secrecy Act obligations, and CFTC commercial forward exclusions.

OFAC Sanctions Compliance

OCRE maintains a zero-tolerance policy toward sanctions evasion. Every participant — buyer, seller, broker, and beneficial owner — is screened against the full suite of OFAC sanctions programs before account opening, at every physical clearing event, and during ongoing periodic re-screening. Our automated pipeline processes the complete Specially Designated Nationals (SDN) list, Sectoral Sanctions Identifications (SSI) list, and all relevant country-based sanctions programs.

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Real-Time SDN Screening
Sub-second automated screening against OFAC's complete sanctions database on every contract origination and warrant transfer. No manual overrides permitted.
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Continuous Monitoring
Daily re-screening of all active counterparties. Any new SDN match triggers immediate account freeze and compliance review.
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Prohibited Persons
Absolute prohibition on SDNs, blocked entities, and terrorism financing. Operations within comprehensively sanctioned jurisdictions are strictly gated under OFAC General Licenses.
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Regulatory Reporting
Automated generation of SARs, CTRs to FinCEN, and strict transaction reporting to the U.S. State and Treasury Departments as mandated by applicable General Licenses.
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Legal Structure
Delaware C-Corp (OCRE Inc.) with principal operations in Miami. Structured to qualify for the CFTC commercial physical Forward Contract Exclusion.
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Data Protection
SOC 2 Type II compliant data handling. All PII encrypted at rest and in transit with post-quantum algorithms.

Rejection & Escalation

Any positive or partial match against sanctions lists triggers an immediate hold. OCRE's Compliance team conducts manual review within 24 hours. Confirmed matches are reported to OFAC and all associated accounts are permanently blocked. False positives are documented with full audit trails. There is no appeals process for confirmed SDN matches — this is federal law, not policy.

Compliance Pillars

  • Pre-trade screening on all counterparties with real-time SDN list synchronization
  • Tiered KYC with Enhanced Due Diligence (EDD) for Politically Exposed Persons and high-risk jurisdictions
  • Continuous transaction monitoring with automated suspicious activity detection algorithms
  • Quarterly independent compliance audits by nationally recognized examination firms
  • Board-level Compliance Committee with independent oversight authority
  • Mandatory annual compliance training for all employees and institutional participants

Compliance Inquiries

For compliance-related questions, audit requests, or regulatory inquiries, contact our Chief Compliance Officer.

Contact Compliance