Global Integrity Framework (G-IF) and Compliance Policy

B1 SIAM GLOBAL TRADE CO., LTD. considers its Global Integrity Framework (G-IF) not merely a regulatory necessity, but the core operating system that underpins all high-value transactions. This framework ensures our financial and operational resilience, maintaining access to critical international liquidity and banking channels.

1. Foundation and Governing Law

Our G-IF is structurally bound by our domicile jurisdiction while incorporating the highest international benchmarks for secure global commerce.

  • Primary Legal Domicile: The Kingdom of Thailand. Our program operates under the strict purview of Thai law, primarily the Anti-Money Laundering Act B.E. 2542 (1999) and the Counter-Terrorism and Proliferation of Weapons of Mass Destruction Financing Act B.E. 2559 (2016).

  • Regulatory Oversight: We maintain continuous dialogue and adherence to directives issued by the Anti-Money Laundering Office (AMLO), ensuring full compliance with national reporting and risk mitigation mandates.

  • Commercial Prerequisite: The integrity of this framework is the critical enabler for our Structured Trade Finance (STF) capabilities, granting us access to international loan and capital markets.

2. Global Sanctions Policy and Risk Posture

Our sanctions policy is explicitly designed to minimize geopolitical risk exposure across our extensive supply and demand corridors.

  • Mandatory Enforcement (UNSCRs): B1 SIAM GLOBAL TRADE mandatorily enforces all asset freezes and prohibitions set forth by the United Nations Security Council Resolutions (UNSCRs), as officially implemented by the Thai government. Compliance with these mandates is non-negotiable and immediate.

  • Risk Mitigation (OFAC & EU Policy): To secure our position within the global banking and insurance ecosystems, we maintain a corporate policy of Zero Tolerance regarding business activity (direct or indirect) involving entities, individuals, or vessels designated on the U.S. OFAC Specially Designated Nationals (SDN) List or the European Union (EU) Sanctions List.

  • Policy Statement: We will not initiate or continue any commercial or financial dealings with sanctioned parties or prohibited entities under the above lists. This proactive stance protects B1 SIAM and our clients from secondary sanctions and reputational risk, securing accelerated trade flows.

3. Integrity in Counterparty Selection

The onboarding process is designed to confirm the legitimacy and stability of every commercial partner, transforming potential counterparty risk into assured operational trust.

  • Risk-Based Approach (RBA): We employ a sophisticated RBA, dedicating compliance resources commensurate with the inherent risk posed by the counterparty, the jurisdiction, the product being traded, and the complexity of the transaction structure.

  • Trade-Based Money Laundering (TBML) Controls: Our compliance team rigorously verifies the economic rationale of all transactions, including the authenticity of underlying documents (e.g., Bills of Lading, Certificates of Origin) and alignment of pricing with global market valuations to prevent the misuse of trade finance channels.

  • Beneficial Ownership Verification: Comprehensive measures are taken to identify and verify the ultimate beneficial ownership of all corporate counterparties, ensuring transparency and accountability in every step of the transaction chain.

4. Ethical Trade and ESG Governance

Our G-IF extends to the physical commodities themselves, ensuring that our supply chain adheres to global ethical and sustainability standards.

  • Supply Chain Integrity: We implement robust due diligence procedures focused on Environmental, Social, and Governance (ESG) factors at the source, particularly concerning ethical labor practices, anti-corruption, and responsible resource management, especially within the Soft Commodities vertical.

  • Internal Oversight: Our compliance framework is supported by continuous employee training, robust internal controls, and a formalized reporting structure directly accountable to senior management.

  • Independent Assurance: The effectiveness and implementation of the G-IF are subject to mandatory, regular independent testing and external audit to validate our operational adherence and maintain the confidence of our financial partners.

Signed and Executed by Managing Director Talant Mambetov