13. TRANSPARENCY
FWD Employees may not knowingly change, alter, delete, exclude or otherwise modify transaction or payment details or information with the intent to disguise or conceal the existence of a party, jurisdiction or other element that might involve sanctions, money laundering or terrorist financing related concerns.
Furthermore, no FWD Employee may use, or recommend the use of, a ‘cover payment’ as a vehicle for effecting a payment with the intent to disguise or conceal the true parties or jurisdictions in interest.