CSR Mercuria 2019 - Flipbook - Page 35
tion and procedural violations, as well as to conduct a thorough review, escalation, analysis and,
where necessary, remediation of such behaviors.
The automation and continued optimization of
these tools provide us with the ability to reduce
false positives from each of the report outputs,
as well as to streamline our process to be able to
more quickly investigate and resolve potentially
legitimate alerts.
Mercuria currently has a suite of surveillance tools
in place that enables us to monitor for high risk
manipulative behaviors and to surveil our communications. Mercuria will continue to assess
the global market risk landscape to identify areas
of increased manipulative market behavior. We
will continue scale up and dynamically add tools
and reporting capabilities that will serve to better
mitigate these risks as they present themselves.
Mercuria’s Business Principles
Mercuria takes seriously its responsibility to ensure it complies with international sanctions,
and to not engage in any commercial or financial
activity that could be construed to benefit any
sanctioned person, entity or country. Accordingly, Mercuria has implemented within its Global
Compliance program a comprehensive sanctions compliance strategy. This includes robust
due diligence and screening of counterparties
prior to onboarding, vessels prior to chartering or
bunkering, and related third parties. Through our
contracts and services agreements, Mercuria requires that all counterparties, service providers,
brokers, intermediaries and joint ventures affiliated with Mercuria be in full compliance with the
principles of this program - including the global
sanctions compliance strategy.
Through the global KYC process, Mercuria thoroughly vets and screens all third parties with
whom we endeavor to conduct business. This
review includes a thorough vetting of all third party articles of incorporation, ownership structure,
and detail of any individuals owning 25% or more
of any upstream ownership company. KYC then
does an incremental screening of the third party
and its upstream ownership via the Dow Jones
Risk and Compliance portal. This provides confirmation that the third party, its principals, affiliates,
and any individual with a 25% or greater ownership interest are not sanctioned.
Additionally, a global vessel screening policy has
been implemented to ensure that all vessels being
offered, receiving product for and delivering product to Mercuria are in compliance with all international sanctions and laws prior to execution of
any agreement for bunkering or chartering. Mercuria utilizes a first-in-class third party application
to conduct its vessel compliance screening and
tracking. Under certain circumstances when a
vessel has a history (in the past 12 months) of
having been to a high-risk jurisdiction or a sanctioned country, Mercuria will require representation from vessel owners confirming that all prior
voyages have been conducted in compliance
with international sanctions and laws in order to
be able to proceed with a transaction.
Mercuria also utilizes termination provisions within its contracts in the event of any sanctions designations.
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