Compliance that protects business without slowing it down.

Why Compliance Matters

Building confidence through effective governance.

Commodity businesses increasingly face regulatory expectations that extend far beyond customer onboarding. Organisations are expected to understand their counterparties, monitor transactions, maintain effective governance, demonstrate financial crime controls and retain comprehensive audit records.

Weak compliance frameworks can expose the business to regulatory sanctions, financial loss, transaction failure, banking disruption and reputational damage.

SAFE develops practical compliance programmes that support commercial activity while maintaining appropriate governance, oversight and accountability.

01 Understand

Assess compliance maturity, regulatory exposure, business activities and the principal sources of financial crime risk.

02 Strengthen

Develop practical frameworks, controls and responsibilities without introducing unnecessary bureaucracy.

03 Protect

Reduce sanctions, AML, fraud, transaction, operational and reputational exposure.

04 Support Growth

Create scalable compliance structures capable of supporting new markets, counterparties, products and jurisdictions.

SAFE CFC Framework™

An integrated compliance and financial crime operating model

The SAFE Compliance & Financial Crime Framework™ connects governance, counterparty integrity, financial crime controls, trade and transaction controls, monitoring and assurance within one coherent operating model.

It is designed to help organisations move beyond isolated policies and screening tools towards a practical framework in which people, processes, technology and oversight work together.

Governance & Accountability

Board and management oversight, delegated authority, policies, risk appetite, accountability and compliance culture.

Customer & Third-Party Integrity

KYC, KYB, beneficial ownership, PEPs, adverse information, source of funds, source of wealth and third-party due diligence.

Financial Crime Controls

AML, CTF, sanctions, anti-bribery, high-risk jurisdictions, export restrictions and escalation.

Trade & Transaction Controls

TBML indicators, documentary review, shipping and vessel risk, route analysis, pricing anomalies, payment structures and trade finance.

Monitoring & Assurance

Ongoing monitoring, periodic reviews, exception management, regulatory reporting, internal assurance and control testing.

Records & Evidence

Decision records, approvals, document retention, audit trails, regulatory readiness and defensible evidence.

Training & Continuous Improvement

Role-based training, policy awareness, incident learning, remediation and continuous development of the control environment.

Commodity Trading Compliance

Commodity compliance requires specialist market knowledge.

Commodity trading presents compliance challenges that generic AML frameworks may not fully capture. Cross-border logistics, vessels, ports, trade finance, letters of credit, warehouse receipts, complex ownership structures, pricing formulas and multi-jurisdictional payments create distinctive financial crime and sanctions risks.

SAFE combines commodity-market experience with governance and financial crime expertise to develop compliance programmes that reflect how physical transactions are actually originated, structured, documented, financed, transported and settled.

Trade-Based Money Laundering

Identify documentary inconsistencies, pricing anomalies, unusual trade structures, false invoicing, phantom shipments and other TBML indicators.

Sanctions, Shipping & Export Controls

Assess restricted parties, jurisdictions, vessels, flags, ports, routes, prohibited goods, dual-use concerns and licensing obligations.

Counterparty & Transaction Integrity

Verify ownership, commercial purpose, payment routing, reputation, trade history, counterparties and transaction rationale.

Compliance in the Transaction

The control framework must follow the trade, not stop at onboarding.

SAFE helps clients connect counterparty due diligence with the actual transaction, including goods, origin, destination, vessels, documents, payment flows, intermediaries and commercial purpose.

This creates a defensible record of why the business was accepted, how risks were assessed and what monitoring or approvals were applied.

Risk-Based Compliance

Direct resources towards the areas of greatest exposure.

A proportionate compliance programme does not treat every counterparty or transaction in the same way. It differentiates risk using the nature of the customer, ownership, jurisdiction, products, transaction structure, delivery route, payment method and other material indicators.

SAFE helps clients design transparent methodologies that connect risk assessment to due diligence depth, approval authority, monitoring frequency and escalation.

Enterprise Risk Assessment

Assess business-wide exposure across customers, products, jurisdictions, delivery channels, transactions and third parties.

Customer Risk Classification

Create documented scoring and classification methodologies for onboarding, EDD and periodic review.

Transaction Monitoring

Define scenarios, red flags, escalation thresholds and review procedures relevant to the organisation’s business model.

Periodic Review & Trigger Events

Set review cycles and event-driven reassessment for ownership changes, sanctions, adverse information and unusual activity.

Governance & Internal Controls

Compliance becomes effective through clear responsibility and evidence.

Strong compliance depends on documented governance, defined accountabilities, appropriate segregation of duties, reliable approval workflows and management information that allows leadership to identify weaknesses and intervene.

Compliance Governance

Board and senior-management oversight, committee structures, delegated authority, reporting lines and accountability.

Policies & Procedures

Risk-based policies, operating procedures, escalation rules, recordkeeping requirements and role-specific guidance.

Approval Workflows

Documented onboarding, EDD, transaction, exception and high-risk approval processes.

Independent Monitoring

Control testing, quality assurance, management review, issue tracking, remediation and internal audit support.

Technology-Enabled Compliance

Technology should strengthen governance, not replace judgement.

Effective compliance requires structured information, documented decisions, reliable workflows and a complete audit trail.

SAFE helps clients define compliance-data requirements, registers, document controls, alerts, approvals, dashboards and record-retention arrangements.

Where appropriate, TradeDesk can support integrated KYC and compliance records, counterparty relationships, document tracking, status history, alerts and transaction-linked evidence.

How SAFE Works

Practical implementation, not theoretical reports.

SAFE works alongside clients to develop compliance frameworks that can be implemented, maintained and continuously improved.

Engagements may address a focused control weakness, a complete compliance programme, technology implementation or remediation following internal, banking or regulatory review.

01 Assess

Evaluate governance, business activities, compliance maturity, regulatory exposure and control effectiveness.

02 Design

Develop the target framework, policies, risk methodology, procedures, controls and implementation roadmap.

03 Implement

Support documentation, workflows, technology, governance, training and organisational change.

04 Improve

Review effectiveness, test controls, remediate weaknesses and support continued development.

Who We Support

Designed for organisations operating across regulated and international markets.

Our approach is particularly suited to firms that require credible compliance capability without importing the cost and bureaucracy of a large financial institution.

Commodity Trading Companies

Principal trading firms managing international counterparties, physical transactions, shipping and trade finance.

Commodity Brokers & Intermediaries

Businesses managing introductions, third-party relationships, mandates and cross-border commercial activity.

Trading, Shipping & Logistics Businesses

Organisations exposed to vessels, routes, ports, documentation, agents and international trade restrictions.

Financial Institutions

Banks, payment firms, investment businesses and specialist institutions requiring commodity-sector insight.

Family Offices & Investment Managers

Investment organisations requiring proportionate AML, sanctions, governance and counterparty frameworks.

Industrial Commodity Consumers

Businesses managing procurement, suppliers, origin, logistics and cross-border payments.

Growing SMEs

Firms building scalable compliance capability to support banking relationships, expansion and institutional counterparties.

Professional & Market Service Providers

Consultants, introducers, agents and service providers operating within commodity and financial markets.