Risk and Compliance
Our counterparties include banks, sovereign agencies and institutional buyers. We are structured to meet the standards they apply.
Compliance in physical commodity trade is not a documentation exercise. It determines which counterparties we can trade with, which banks will finance a cargo, and whether a transaction settles at all. We treat it as a commercial function rather than an administrative one.
Our Framework
Our framework covers counterparty due diligence, sanctions screening, anti-money-laundering controls, anti-bribery and corruption requirements, market conduct and documentary integrity. It is supported by written policies, defined approval responsibilities, record-keeping and periodic review.
Responsibility sits with management and with the commercial team, not with a single function. A control that only a compliance officer enforces is not a control.
Counterparty Due Diligence
We assess every counterparty before trading — legal identity and beneficial ownership, jurisdiction and regulatory standing, the commercial coherence of the proposed transaction, and adverse-association screening. Records are maintained and reviewed on a continuing basis, and relationships are re-examined when circumstances change. A counterparty acceptable at onboarding is not permanently acceptable.
- Legal identity and beneficial ownership verified before trading
- Jurisdiction, regulatory standing and adverse-association screening applied to every counterparty
- Records reviewed on a continuing basis, not only at onboarding
- Relationships re-examined whenever circumstances change
Sanctions
Counterparties, beneficial owners, vessels and jurisdictions are screened against applicable sanctions regimes before a trade proceeds. Where a transaction involves a restricted party or jurisdiction, or where screening raises a question we cannot resolve, we decline it. The commercial value of the trade does not enter that assessment.
- Counterparties, beneficial owners, vessels and jurisdictions screened before every trade
- Restricted parties or jurisdictions are declined outright
- An unresolved screening question means the trade does not proceed
- Commercial value never enters the assessment
Anti-Money Laundering
We apply anti-money-laundering controls consistent with applicable law and established international practice. Transactions are assessed for commercial rationale as well as documentary correctness. Payment structures that do not correspond to the underlying trade — third-party payers, unexplained routing, terms inconsistent with the commercial relationship — are escalated before the trade proceeds.
- Controls consistent with applicable law and established international practice
- Transactions assessed for commercial rationale, not just documentary correctness
- Third-party payers, unexplained routing and inconsistent terms are escalated before proceeding
Anti-Bribery and Corruption
We hold a zero-tolerance position on bribery and corruption. No improper payment, gift or benefit is offered, solicited or accepted in connection with any trade, financing, customs, inspection or regulatory matter, in any market. This standard applies without adjustment for local practice, and it extends to agents and intermediaries acting on our behalf.
- Zero tolerance on bribery and corruption, in every market
- No improper payment, gift or benefit — offered, solicited, or accepted
- Applies without adjustment for local practice
- Extends to agents and intermediaries acting on our behalf
Documentary Integrity
All documentation we issue reflects the underlying transaction. We neither issue nor accept documents that misstate the quantity, quality, value, origin or timing of goods. Documentary integrity is the basis on which banks accept our presentations.
- Every document we issue reflects the underlying transaction
- No documents that misstate quantity, quality, value, origin or timing
- Pressure to compromise documentary integrity is treated as a reason to withdraw from a trade
Market and Position Risk
Positions are taken within defined limits and against assessed risk. Price, currency and counterparty exposure is measured before a position is established and managed through to settlement. Where we transact on regulated exchanges, we do so in accordance with the rules of those markets.
- Positions taken within defined limits against assessed risk
- Price, currency and counterparty exposure measured before a position is established
- Exposure managed through to settlement, not just at trade inception
Contract Standards
Physical trades are concluded on recognised international trade association standard forms — GAFTA and FOSFA for grains and edible oils, and the standard forms of The Sugar Association of London and The Refined Sugar Association for sugar. These forms provide established arbitration and quality-determination mechanisms and a common frame of reference between counterparties operating under different legal systems.
- Concluded on recognised international trade-association standard forms
- Established arbitration and quality-determination mechanisms built in
- A common frame of reference across counterparties in different legal systems
For counterparty due diligence or KYC documentation requests, contact our desk directly. We respond to all documentation requests promptly.
Compliance Enquiry