Governance, compliance and risk
ANF operates in sectors and jurisdictions where the quality of a counterparty's compliance posture is itself a commercial asset. Our framework is built to satisfy the due diligence requirements of banks, refiners and institutional investors before they ask.
Counterparty due diligence
KYC verification of identity, corporate registration, beneficial ownership and authority to act, for every party to every transaction. Enhanced due diligence where a transaction involves a higher-risk jurisdiction, a politically exposed person, a complex ownership chain, or an intermediary in the payment path. Source of funds and wealth enquiry proportionate to value and risk. Allocation, refinery and supply credentials verified at source rather than by reliance on documents circulated between intermediaries.
Anti-money laundering and counter-terrorism financing
ANF maintains policies and procedures directed at compliance with applicable AML/CTF obligations, including customer identification, ongoing monitoring, record keeping, and the escalation and reporting of suspicious matters. Staff receive periodic training appropriate to their role.
Sanctions and trade controls
All counterparties, beneficial owners, vessels, cargoes and countries of origin are screened against measures administered by the United Nations, Australia, the European Union, the United Kingdom and the United States. Where a transaction cannot be completed lawfully, it does not proceed — without exception and irrespective of the commercial consequence.
Anti-bribery and corruption
ANF prohibits the offering, promising, authorising or provision of any improper payment or advantage, directly or through a third party. ANF’s margin is earned as principal on its own sale, in a genuine commercial transaction.
Contractual risk management
Every sale is governed by a written contract addressing specification, quantity and tolerance, delivery and risk transfer, inspection, pricing, payment security, title, force majeure, confidentiality, governing law and dispute resolution. Governing law and forum are selected by reference to enforceability against the counterparty’s assets rather than by convention.
Credit and performance risk
As seller, ANF carries counterparty credit and performance risk itself. Credit limits are set before contracting, exposure is monitored for the life of the transaction, and payment risk is mitigated through documentary credits, standby instruments, prepayment, parent guarantees or credit insurance as the counterparty and jurisdiction require.
Information security
Counterparty identities, transaction terms and commercial documentation are treated as confidential and held on controlled systems with access restricted to the personnel working on that transaction.
Independent oversight
Legal, financial and operational functions are separately led, and transactions are subject to internal review independent of the executive responsible for origination.