Compliance Policy of ASIACOM Group
The ASIACOM Group operates in multiple jurisdictions and is subject to strict expectations from banks, customs and regulators. To meet these expectations, Group-wide compliance rules are defined and maintained by Tokyo HQ (Japan Desk).
This page summarizes the key compliance principles, prohibited activities and escalation rules that apply to Hong Kong, Taiwan and Philippine Desks as part of the Group structure.
Compliance Philosophy
ASIACOM adopts a zero-tolerance approach to:
- Violations of sanctions and AML rules
- Illegal or controlled cargo, smuggling or wildlife crime
- Sham or fictitious transactions without economic substance
- Forged, altered or inconsistent documentation
- Non-transparent payment routes or third-country detours
- High-risk or unverifiable counterparties
These rules are designed so that external parties – especially banks and authorities – can clearly see that the Group pro-actively avoids high-risk activities instead of merely reacting when problems occur.
Prohibited Transactions
The following categories of transactions are strictly prohibited across the entire ASIACOM Group, with no exceptions:
Sanctioned and high-risk countries
The Group does not conduct any business involving North Korea, Iran, or any jurisdiction designated as high-risk by banks, governments, OFAC, the UN, FATF or equivalent authorities. This prohibition covers direct transactions, indirect routing and transshipment.
Illegal and controlled goods
ASIACOM does not handle weapons, military-use items, illegal drugs, chemical precursors, wildlife and plants protected under CITES, smuggling-related items, or any cargo that violates export control, customs or other laws.
AML-sensitive structures and practices
The Group prohibits sham transactions, documentation mismatches, false or altered documents, unexplained payment routes, third-country routing for the purpose of obscuring origin or destination, unjustified split payments, and dealings with shell companies or non-operating entities.
Counterparty and Trade Compliance
All counterparties must undergo KYC/KYB checks, including identity and registration verification, sanctions screening, beneficial ownership (UBO) checks, and financial and reputational review. High-risk or unverifiable counterparties are rejected.
Trade compliance covers export control, customs requirements and maritime law in each relevant jurisdiction. Documents such as invoices, packing lists and bills of lading must accurately describe the goods and match the payment and shipping structure. Forgery or manipulation is not allowed.
Data, AI and Privacy Compliance
ASIACOM complies with applicable data protection laws such as Japan’s APPI, Hong Kong’s PDPO, Taiwan’s PDPA and the Philippines’ DPA. Personal and confidential information is handled carefully and only for legitimate business purposes.
AI systems, including the Group AI assistant “Ive”, are managed under the AI Governance Standard of Tokyo HQ. Only trusted, non-Chinese AI providers are used, and internal rules define what data can be used with AI tools. Important compliance-related decisions always remain under human control.
Reporting, Escalation and Enforcement
All Desks must promptly report any suspected violation of this Policy to Tokyo HQ. The following must be escalated without delay:
- Requests involving sanctioned or high-risk countries
- Suspicious or unusual transaction structures
- Inconsistent or altered documentation
- Unusual payment flows or offshore banks
- Potential illegal or controlled goods
- Inquiries or warnings from regulators or banks
Violations of the Group Compliance Policy may lead to termination of the transaction, termination of the business relationship, internal disciplinary action and, where appropriate, reporting to banks or authorities. Serious cases may result in permanent blacklisting of counterparties.
This Policy is reviewed at least annually by Tokyo HQ, or earlier when AML, sanctions or data/AI regulations change.