Client Screening, Sanctions and Anti-Bribery

A service that restores access to platforms and places stories in publications is attractive to exactly the people it should refuse. This page sets out what we check and what we will not do at any fee, so that a prospective client can see it before making an enquiry and decide not to waste the exchange.

Sanctions and restricted parties

• We do not act for any person or entity on a sanctions list maintained by the United States Office of Foreign Assets Control, the United Nations, the United Kingdom or the European Union, nor for anyone owned or controlled by one.
• We do not act for a person or entity in a comprehensively sanctioned territory, or where the work would breach an export control or trade restriction.
• We screen the contracting party and, where a matter concerns a business, its named beneficial owners, before engaging, and again if the picture changes.
• If a screening hit appears mid matter, we stop work immediately, we tell you that we have stopped, and we do not return funds where doing so would itself be prohibited. We will say so plainly rather than go quiet.

Knowing who we are acting for

• We verify that the person instructing us controls, or is authorised to act for, the account or business the matter concerns. This is the single most important check in this category, and it protects the real account holder more than it protects us.
• We will not act to obtain access to an account on behalf of someone who is not its owner or an authorised representative. Where ownership is genuinely disputed, that is a matter for the platform's own process or a court, and we say so.
• We ask where funds are coming from where the size or the structure of a payment does not match the matter, and we do not accept cash, third party payments from unconnected parties, or payment routed to avoid a paper trail.
• We keep a record of what we checked and when, for the period in our Data Retention Schedule.

Bribery and inducements, the absolute rule

• We do not pay, offer or promise anything of value to an employee, contractor or moderator of a platform, a publication or a regulator, in order to influence a decision. Not a fee, not a gift, not a favour, not a job offer, not free work.
• We do not use an intermediary to do it either. Engaging someone who says they have an inside contact is the same act with an extra step, and it is the single most common way clients in this category are defrauded.
• We do not pay a journalist or editor for coverage presented as editorial. Paid placement is possible and legitimate, and where it is used it is bought openly and labelled as advertising. Our Marketing and Advertising Standards page states this as a rule we hold ourselves to.
• We do not offer or accept a kickback for a referral without disclosing it to you first.
• Anyone offering to make a problem disappear through a contact inside a platform is either defrauding you or committing an offence, often both. Report it and do not pay.

Matters we refuse outright

• Obtaining access to an account you do not own or are not authorised to act for.
• Buying, selling, renting or transferring an account, a handle or a verification badge.
• Suppressing accurate reporting of a criminal conviction, a regulatory finding, a court judgment or a safety matter.
• Anything designed to conceal a fraud on consumers, investors or a court.
• Work for a party whose underlying conduct is the reason for the restriction and who intends to resume it.
• Anything that requires us to make a false statement to a platform, a publication or a regulator. Every submission we write must be true, because a submission that is not is the fastest way to lose an appeal permanently.

We would rather refuse a paying matter than take one we would have to lie in. This is not a moral flourish. A single fabricated appeal poisons every future filing we make on the same route.

Reporting

If you believe anyone acting in our name has breached this policy, tell the desk at sales@goldlabelmedia.net. We investigate every report, we do not retaliate against anyone who makes one in good faith, and where an offence appears to have been committed we report it.