Every counterparty and every transaction is checked first
Every counterparty and transaction must pass our compliance framework before any contract is signed or any cargo or metal moves.
Know Your Customer
Verification of company registration, ultimate beneficial owners, directors and authorised signatories, refreshed according to risk.
Anti-Money Laundering
Procedures aligned with UAE Federal Decree-Law No. 20 of 2018 and its regulations, with suspicious activity reporting to the UAE FIU through goAML.
Sanctions screening
Screening against UN, UAE, OFAC, EU and UK sanctions lists for parties, vessels, ports and product origin.
Origin verification
Independent inspection, certificates of origin and quality, and complete chain-of-custody records.
Contract and payment security
Bank-to-bank instruments, Incoterms 2020 and clearly defined dispute-resolution clauses.
Record keeping
Transaction and due-diligence records retained for the period required under UAE law.
Three independent layers of control
Compliance Officer / MLRO: Dr. IM PANHAVUTH, reporting independently to the Board.
| Line | Who | Responsibility |
|---|---|---|
| First line | Trading and operations teams | Apply KYC, screening and documentation controls on every transaction |
| Second line | Compliance Officer / MLRO | Sets policy, approves high-risk counterparties, monitors and reports |
| Third line | Independent audit | Periodic review of the effectiveness of controls, reported to the Board |
Protection of capital first, returns second
Every trade must be backed by physical product, a verified counterparty and secured payment. Risk limits are approved by Board Resolution and reviewed at least once a year.
Investment principles
- Capital preservation: capital only in physical trades with defined downside and secured payment.
- Physical focus: no speculative paper positions unrelated to physical flows.
- Diversification across products, counterparties, regions and delivery periods.
- Liquidity: a cash and credit reserve for margin calls, freight and inspection costs.
Hedging
- Oil price exposure hedged with ICE Brent, Platts or NYMEX futures or swaps.
- Gold price exposure hedged with futures or forward sales, or avoided through back-to-back pricing.
- Foreign-exchange exposure on non-USD contracts hedged once a contract is signed.
- Hedging only reduces risk on physical positions; it is never a standalone profit activity.
Counterparty and credit
- KYC, AML and sanctions checks and an internal credit rating before trading.
- Open-account credit only for rated counterparties within approved limits.
- All others pay by letter of credit, standby letter of credit or bank guarantee.
- Credit insurance used where available for larger exposures.
No document, no movement
Every transaction is executed safely, on time and exactly as contracted, with a complete document trail from contract to settlement.
Segregation of duties
Trading, operations and logistics, and finance and settlement are handled by separate people.
Four-eyes principle
Contracts, payments and release of title documents need two authorised signatures.
Document control
Product or metal is not released, and payment is not made, until all required documents are verified.
Independent verification
Quality and quantity are always confirmed by an independent inspector or accredited assayer.
Health, safety and environment
We work only with terminals, vessels, refineries and carriers that meet recognised standards. Marine fuels comply with MARPOL Annex VI.
Business continuity
Off-site backups, trained alternates for key roles, and alternative suppliers, vessels and carriers on each main route.
Clear accountability at every level
The company is managed on clear accountability, defined decision rights and regular, transparent reporting, so every decision can be traced to an authorised person. All policies are reviewed by the Board at least annually.
- Code of conduct for all staff and directors
- Zero tolerance for bribery and corruption
- Mandatory declaration of conflicts of interest
- Confidential whistleblowing channel
- Compliance training at onboarding and at least annually
- Annual financial statements audited independently under IFRS
Our seven-stage transaction process
Recognised international trade practice, giving buyers and sellers full clarity at every stage.
Enquiry
The buyer submits a Letter of Intent (LOI) or Request for Quotation with product, quantity, delivery terms and destination.
Due diligence
We complete KYC, AML and sanctions screening on the counterparty.
Offer
We issue a Full Corporate Offer (FCO) with price basis, specification and commercial terms.
Contract
Both parties execute a Sales and Purchase Agreement (SPA).
Payment instrument
The buyer's bank issues the agreed DLC, SBLC or other instrument, verified bank to bank.
Inspection and delivery
Product is independently inspected for quality and quantity and delivered under the agreed Incoterm.
Settlement
Payment is released against shipping documents, inspection certificates or assay reports.
Discuss a cargo, a term supply or a gold purchase.
Send your Letter of Intent or Request for Quotation. Every enquiry is answered by a member of our trading team after counterparty checks.