Compliance is part of the price of doing business — not a checkbox
Counterparties in commodity trading — banks, refiners, manufacturers, regulators — increasingly demand visible compliance discipline. We treat it as a precondition for every transaction, not a hurdle to negotiate around. The five pillars below describe how we operate.
OECD Due Diligence for Mineral Supply Chains
All metals and minerals sourcing follows the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. We screen producers, intermediaries, and transit jurisdictions against the five-step OECD framework and document the diligence trail on every cargo.
- → Producer KYC including beneficial-ownership verification
- → Origin-country risk assessment (conflict, governance, human rights)
- → Transit route and intermediary screening
- → Documented audit trail per cargo, retained for review
Sanctions Compliance — EU, OFAC, UK, Swiss SECO
All counterparties, vessels, and transactions are screened against EU, US (OFAC), UK (OFSI), and Swiss (SECO) sanctions lists at onboarding and prior to every transaction. We monitor regulatory changes continuously and re-screen active counterparties on a rolling basis.
- → Sanctions list screening at onboarding + per-transaction
- → Vessel screening (IMO, flag, prior port calls, ownership)
- → Trade-restriction monitoring (oil price caps, dual-use, export controls)
- → Documented refusal of business where sanctions risk exists
EU Critical Raw Materials Act Readiness
The EU Critical Raw Materials Act (CRMA) and Battery Regulation impose increasing traceability requirements on critical and battery metals entering the EU market. We structure our sourcing and documentation to support clients' CRMA, battery passport, and conflict-minerals reporting obligations.
- → Origin documentation for CRMA strategic and critical raw materials
- → Battery passport data support for lithium, cobalt, nickel, manganese
- → Conflict minerals reporting (tin, tantalum, tungsten, gold)
- → Supply-chain transparency for downstream regulatory needs
AML, KYC & Counterparty Diligence
Anti-money-laundering and KYC discipline applies to every counterparty — producers, intermediaries, buyers, financiers. Our procedures align with Swiss FINMA expectations for trade-finance counterparties and with international AML standards (FATF).
- → Beneficial-ownership identification
- → Source-of-funds verification
- → Politically Exposed Persons (PEP) screening
- → Enhanced due diligence for higher-risk jurisdictions or sectors
Marine HSE & Operational Standards
Our marine and offshore service work operates with explicit focus on Health, Safety, Environment, and Quality (HSEQ) — in line with the standards expected by Petroleum & Gas operators, Offshore Construction Contractors, and shipowners. Bunkering and marine fuel quality are verified per cargo.
- → HSEQ-aligned marine operations and inspections
- → Bunker fuel quality and quantity verification per delivery
- → IMO sulphur regulation compliance (IMO 2020)
- → Marine claims and incident reporting protocols
What We Will Not Do
A clear list, in plain language. If a deal touches any of these, we walk away — regardless of the margin on offer.
- ✗Transactions involving entities, vessels, or cargoes subject to EU, OFAC, UK, or Swiss sanctions.
- ✗Metals or minerals sourced from artisanal operations involving child labour or forced labour.
- ✗Cargoes from conflict-affected production where OECD due diligence cannot be substantiated.
- ✗Counterparties unwilling to complete KYC, source-of-funds, and beneficial-ownership disclosure.
- ✗Transactions designed to evade trade restrictions, price caps, or export controls.
Request Our Compliance Statement
Banks, offtakers, and counterparties can request our standard compliance documentation package directly.
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