Sobranes, LLC

The Mountain

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Ethics and Compliance


            We abide by several sources and guidelines for our performance. We look to the rules, laws and suggested course of conduct by the United states Government, and the various texts of conducting oneself in international business.

            Sobranes also has some internal canons of ethics of its own. These canons are the result of working with many people in different lands and recognizing that we will conduct ourselves, and hold ourselves to a standard which, inmost instances, is much higher than the standards imposed by laws or other governments, and even by other people.

            Our rules and ethics guide us in our inter-actions with our colleagues around the world so that we can conduct ourselves at all times with the degree of clarity and authenticity we seek.


Compliance with Foreign Corrupt Practices Act of 1977, codified as amended at 15 U. S. C. §§ 78m, 78dd, and 78ff. See

Compliance with Dodd-Frank Section 1502, See

Anti-money Laundering policy

Compliance with U.S. Patriot Act. See

Sobranes has read and reviewed, and hereby affirms its intention to abide by the stated purposes of the Act, which are:

  • To strengthen U.S. measures to prevent, detect and prosecute international money laundering and financing of terrorism;
  • To subject to special scrutiny foreign jurisdictions, foreign financial institutions, and classes of international transactions or types of accounts that are susceptible to criminal abuse;
  • To require all appropriate elements of the financial services industry to report potential money laundering;
  • To strengthen measures to prevent use of the U.S. financial system for personal gain by corrupt foreign officials and facilitate repatriation of stolen assets to the citizens of countries to whom such assets belong.

This Act pays special attention to areas of our practice, when it comes to the sale and purchase of commodities of great value and the method used to pay for them. See also, which details the Special crimes Enforcement Unit, and their protocols to ensure that there is no money laundering.