1. Our Commitment

EM Credit Financial & Management Ltd. is committed to operating with the highest standards of legal and regulatory compliance. As a company registered in England and Wales and referenced by the Financial Conduct Authority (FCA Reference: 902384), we maintain rigorous compliance frameworks to ensure all business activities meet or exceed the requirements of applicable laws, regulations, and industry standards.

2. Regulatory Framework

Our business operations are governed by and comply with the following key regulatory frameworks:

2.1 United Kingdom

Financial Conduct Authority (FCA): We operate under FCA guidelines applicable to commodity trading activities, including position reporting, conduct of business, and market integrity obligations
Companies Act 2006: Full compliance with company law reporting, record-keeping, and governance requirements
UK GDPR & Data Protection Act 2018: Adherence to UK data protection legislation, with the Information Commissioner’s Office (ICO) as supervisory authority
Data (Use and Access) Act 2025: Compliance with updated data processing and consent provisions effective from February 2026

2.2 International Standards

ICC Incoterms® 2020: All physical commodity transactions reference International Chamber of Commerce delivery terms (e.g., CIF, FOB, DAP, DDP) to ensure clarity and legal certainty
UCP 600: Letters of credit and documentary transactions follow the Uniform Customs and Practice for Documentary Credits
ISDA Standards: Derivative and swap transactions are conducted under applicable International Swaps and Derivatives Association frameworks where relevant

3. Anti-Money Laundering (AML)

EM Credit maintains a comprehensive AML programme in accordance with:

Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended 2022)
Proceeds of Crime Act 2002
FATF Recommendations: Adherence to the Financial Action Task Force’s international standards for combating money laundering and terrorist financing

Our AML measures include:

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk counterparties
Know Your Customer (KYC) identity verification for all trading partners and counterparties
Know Your Transaction (KYT) monitoring to detect unusual or suspicious trading patterns
Suspicious Activity Reports (SARs) filed with the National Crime Agency (NCA) as required
Regular staff training on AML obligations and red flag indicators
Appointment of a designated Money Laundering Reporting Officer (MLRO)

4. Sanctions Compliance

EM Credit strictly adheres to all applicable sanctions regimes. We do not engage in business with sanctioned individuals, entities, or jurisdictions and maintain continuous monitoring of:

OFSI: HM Treasury Office of Financial Sanctions Implementation — UK financial sanctions list
OFAC: US Office of Foreign Assets Control — Specially Designated Nationals (SDN) list and sectoral sanctions
EU Sanctions: European Union restrictive measures and consolidated list
UN Security Council: United Nations sanctions committee consolidated list

All counterparties, beneficial owners, and transaction chains are screened against these lists prior to and during the course of any business relationship. We employ regular re-screening and monitoring to ensure ongoing compliance.

5. Anti-Bribery and Corruption

EM Credit has zero tolerance for bribery and corruption in accordance with:

UK Bribery Act 2010: Including provisions on bribing another person (Section 1), being bribed (Section 2), bribing a foreign public official (Section 6), and failure of commercial organisations to prevent bribery (Section 7)
US Foreign Corrupt Practices Act (FCPA): To the extent applicable to our international transactions

We maintain policies covering gifts and hospitality, facilitation payments, and the use of agents and intermediaries. All personnel are required to comply with our anti-bribery policies and participate in regular training.

6. Market Conduct

We are committed to fair and transparent market conduct. Specifically:

Market Abuse Regulation (UK MAR): We do not engage in insider dealing, unlawful disclosure of inside information, or market manipulation
Price Reporting: Where applicable, we provide accurate and timely information to Price Reporting Agencies (PRAs) and comply with IOSCO Principles for Oil Price Reporting
Position Limits: Adherence to commodity derivative position limit requirements as set by UK trading venues in accordance with FCA rules effective July 2026

7. International Trade Compliance

All commodity transactions comply with applicable international trade regulations:

Export Controls: Compliance with UK Export Control Act 2002 and the Export Control Order 2008, including licensing requirements for dual-use goods and controlled commodities
Customs Regulations: Adherence to HM Revenue & Customs requirements, including tariff classifications, customs declarations, and country-of-origin rules
International Maritime Organisation (IMO): Compliance with IMO 2020 sulphur cap requirements for marine fuel transactions
Environmental Regulations: Adherence to applicable environmental standards, including EU ETS (Emissions Trading System) requirements for qualifying transactions

8. Counterparty Due Diligence

Before entering into any trading relationship, we conduct thorough due diligence including:

Verification of legal existence and corporate registration
Identification of beneficial ownership structures
Assessment of the counterparty’s regulatory status and standing
Screening against sanctions, PEP (Politically Exposed Persons), and adverse media databases
Evaluation of the commercial rationale and risk profile of proposed transactions
Ongoing monitoring and periodic review of the relationship

9. Record-Keeping

We maintain comprehensive records in accordance with:

FCA record-keeping rules (minimum 5 years, or 7 years where applicable)
AML regulations (minimum 5 years after the end of the business relationship)
Companies Act 2006 obligations
HMRC requirements for tax-related records

10. Whistleblowing

EM Credit encourages the reporting of concerns regarding potential breaches of law, regulation, or internal policy. We have established procedures to ensure that reports can be made confidentially and without fear of retaliation, in accordance with the Public Interest Disclosure Act 1998 and FCA whistleblowing requirements.

11. Reporting a Concern

If you have a compliance concern or wish to report potential misconduct, please contact us:

Email: trading@emcredit.uk
Address: Compliance Department, EM Credit Financial & Management Ltd., A11 2 Alexandra Gate, Cardiff, CF24 2SA, United Kingdom

All reports will be treated confidentially and investigated promptly in accordance with applicable legal and regulatory requirements.