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Risk - Sales Guidance

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Controlling Persons⁠

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Reputational Risk⁠

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PEP’s⁠

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Client Risk: A Guide for Sales

What Should You Think About?

Risk assessment is an art as much as a science. Often it’s just gut instinct. However, there are little flags and signals we read to work out if something is real, or just too good to be true. It’s rare that all the signals will align perfectly, so you need to consider the whole picture. Over time, you’ll develop a strong instinct for when something feels or smells off. More often than not, it’ll be because many of the below just don’t sit quite right. There will rarely be one big fat red flag.

If, for whatever reason, your gut is telling you something isn’t quite right, it is your job to initiate a KYC by starting a Sales FAQ directed at GI and tagging Vincent with a link to the website and company LinkedIn with a summary of your concerns.

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Business Industry

One way to think about risk is as a traffic light system:

Red: Absolute no-go.

Amber: Proceed with caution and escalate for discussion.

Green: Generally low risk.

At Boundless, we have clear guidance on industries that fall into the red and amber categories. Everything else you can take as green.

Red – Absolutely not.

There is only one clear red flag for us:

Military and arms – We will not work with any military contractors or arms manufacturers. If a prospect operates in this space, it’s an automatic no.

Amber – Proceed with Caution

The industries below require a closer look. If you come across a company in any of these sectors, flag it with Nick for an initial discussion. This isn’t an automatic rejection—it just means we need to think carefully before engaging.

These industries tend to operate in a blend of black, white, and grey areas. Some businesses within them may be perfectly legitimate, while others might have questionable ethics, reputations, or legal risks. Our job is to make sure we manage our own

Reputational Risk⁠

, rather than getting pulled into someone else’s mess.

Industries requiring extra scrutiny:

Gambling

Pornography

Natural resources extraction (mining, oil, gas, precious metals)

Chemical manufacturing or supply

Pharmaceuticals

Payday loans and high-interest lending

Waste collection and disposal

Wholesale of hides/skins/leather

Trusts, funds, and financial institutions

Private security firms

Real estate investment and development

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The Entity Type

Not all businesses forms are created equal when it comes to risk. A company’s structure plays a big role in how transparent (or opaque) it is.

A publicly listed company is accountable to shareholders, markets, and regulators. A private company, partnership, trust, or fund is not. These entities often disclose far less information publicly and, in some cases, are designed to be deliberately opaque.

Lower-risk entities:

Publicly listed companies (e.g., IBM) – These have shareholders, regulators, and extensive reporting requirements.

Well-known private companies – Recognised brands tend to have clear governance structures.

Charities – Typically subject to strong oversight and transparency regulations.

Government bodies – Generally safe but may require additional due diligence (e.g., procurement rules, political exposure).

Higher-risk entities:

Privately held businesses – Less public disclosure and often opaque in their ownership structures.

Partnerships (e.g., law firms, Big Four firms) – Often complex structures with varying transparency levels.

Trusts and funds – Can be legitimate but are sometimes designed for secrecy.

Individuals – Always a red flag for deeper due diligence.

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Ownership and Control

Ownership plays a huge part in whether a business passes the sniff test. Owned by the Dalai Lama? Probably fine. Owned by Putin’s right-hand man? Bit spicier. We have full guidance on what Ownership and Control is

here⁠

What to check:

Ownership – Who ultimately controls the company? A quick Google search of the owner’s name can reveal useful insights. If they’ve been in court a lot for debts, probably don’t want to take on that client.

Board of Directors – Just because someone’s an executive doesn’t mean they’re clean. Take a moment to check board members for red flags (e.g., legal issues, financial scandals, corruption allegations). You might be surprised at what you find.

Politically Exposed Persons (PEPs) – These are individuals who hold (or have held) significant public positions, along with their immediate family members and close associates. PEPs pose higher risks due to their potential involvement in bribery, corruption, or money laundering. If you suspect a PEP is involved, flag it immediately. Again, full guidance on PEP’s

here⁠

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The First Date: How Did You Meet?

A client’s origin story matters. It can indicate risk levels before you even dive into the details. We all know about webcams — if it’s off, it’s higher risk. Likewise, a client in a hurry can be a red flag. If someone is trying to rush or pressure you into action, they might be hiding something.

Lower risk:

Face-to-face meetings.

Introductions through trusted sources (existing clients, investors, partners, Dee).

Higher risk:

Cold outreach from the client (especially from an unknown, foreign entity).

No video calls, reluctance to meet in person, or avoidance of direct questions.

A client who is rushing the process – True business emergencies exist, but we operate within a culture of compliance. If a client is pushing too hard to bypass standard checks, take a step back.

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Geography: Where Are They Based?

Some jurisdictions are inherently riskier than others. Risk factors can include sanctions, corruption levels, regulatory environment, and ease of doing business.

Things to check:

Where is the company registered?

Where does it operate? A company might be registered in Ireland (low risk) but actively conducting business in Russia, North Korea, or Sudan (high risk). This will be on their website.

The Financial Action Task Force (FATF) lists provided below identify countries that are considered high-risk or under increased monitoring (grey list, blacklist).

If it’s on the blacklist, it’s probably a no. Grey, a discussion will probably need to be had.

Black List:

Iran

North Korea

Mynanmar

Grey List:

Algeria

Angola

Bulgaria

Burkina Faso

Cameroon

Côte d'Ivoire

Croatia

Democratic Republic of the Congo

Haiti

Kenya

Laos

Lebanon

Mali

Monaco

Mozambique

Namibia

Nepal

Nigeria

South Africa

South Sudan

Syria

Tanzania

Venezuela

Vietnam

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Conclusion: Trust Your Instincts (and Use Your Rubber Duck)

At Boundless, we all get a rubber duck when we join. If you’re unsure about a prospect, talk it through—sometimes explaining something out loud helps you spot the issue. If the duck is awkward, set up a Huddle. But do talk!

Risk isn’t always obvious, but talking it through with someone else can help clarify whether we should move forward or step away. We’d rather slow down and get it right than rush into something we regret.

If something feels off, trust that instinct. When in doubt, ask.

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