Compliance

A clear governance structure with defined accountability across our insurance, escrow, verification, and advisory divisions.

• Board-level oversight of risk, compliance, and fiduciary responsibilities.
• Separation of duties between escrow administration, verification, and underwriting placement.
• Documented delegation of authority and escalation procedures for material decisions.
• Regular governance reviews aligned to international best practice.

A code of ethics that governs every engagement, with independence and honesty as non-negotiable principles.

• We are retained by clients and accept no direction from counterparties, insurers, or marketplaces.
• Findings are reported as the evidence shows — including results a client may not want to hear.
• Conflicts of interest are identified, disclosed, and managed before they affect an engagement.
• Gifts, hospitality, and inducements are governed by a strict anti-bribery policy.

A zero-tolerance stance toward fraud, backed by investigation capability and industry collaboration.

• Dedicated investigators trained in trade-finance and supplier-fraud patterns.
• Red-flag screening on counterparties, documents, and transaction structures.
• Cooperation with clients, insurers, and authorities on suspected fraud.
• Published fraud-pattern research to raise industry awareness.

An AML program designed to prevent our services from being used to launder proceeds of crime or finance illicit activity.

• Transaction monitoring and source-of-funds checks on escrow movements.
• Sanctions-list screening against major international regimes.
• Suspicious-activity identification and escalation procedures.
• Ongoing AML training for all client-facing and fiduciary staff.

Rigorous client and counterparty identification before any engagement begins.

• Identity and beneficial-ownership verification for corporate clients.
• Counterparty screening as part of every verification and escrow engagement.
• Enhanced due diligence for higher-risk jurisdictions and structures.
• Periodic refresh of client information based on risk tier.

Personal and commercial data is treated as a fiduciary responsibility, protected by technical and organizational controls.

• Data minimization — we collect only what an engagement requires.
• AES-256 encryption at rest and TLS 1.3 in transit.
• Role-based access controls with full audit trails.
• Clear retention and deletion schedules for client data.

We align our data-processing practices with the EU General Data Protection Regulation and Thailand's PDPA.

• Lawful bases and transparency notices for personal-data processing.
• Data-subject rights honored: access, rectification, erasure, and portability.
• Data-processing agreements with processors and sub-processors.
• A designated point of contact for privacy inquiries and requests.

A structured framework for identifying, assessing, and controlling the risks we accept on behalf of clients.

• Three lines of defense: operational controls, risk oversight, and independent review.
• Country, counterparty, and transaction risk scoring before acceptance.
• Concentration and exposure limits across the escrow and insurance book.
• Scenario and stress testing of material exposures.

Fair dealing, honest representation, and accountability in every client relationship.

• Clear, written terms for every engagement — no hidden fees or conditions.
• Honest representation of what our services can and cannot guarantee.
• A defined complaints and dispute-resolution process.
• Professional indemnity arrangements appropriate to our services.

A binding code that sets the standard of behavior for every employee, contractor, and network partner.

• Applies equally to staff and to vetted network partners worldwide.
• Covers confidentiality, conflicts, anti-bribery, and professional behavior.
• A confidential channel for reporting concerns without retaliation.
• Regular acknowledgment and training across the organization.

Our standing commitment to operate lawfully, ethically, and to the standards our clients expect.

• We operate under the supervision of our compliance function and external advisers.
• We do not claim licenses, authorizations, or certifications that have not been formally granted.
• Regulatory and certification status is published as each process is completed.
• Clients may request our current compliance position in writing at any time.