Risk Management Framework of ASIACOM Group
ASIACOM manages risk on a Group basis, with Tokyo HQ acting as the central control center. The risk framework is built around international AML standards and is designed to satisfy the expectations of banks, customs, port authorities and regulators.
Hong Kong functions as the frontline commercial hub, while Tokyo HQ supervises AML and sanctions risk, trade and operational risk, data and AI risk, and geopolitical and counterparty risk for the entire Group.
Key Risk Areas
The Group focuses on four main categories of risk:
- AML & sanctions risk – avoiding high-risk countries, illegal cargo and suspicious transactions.
- Trade & operational risk – contracts, documents, ports, logistics and payment structures.
- Data & AI risk – safe use of non-Chinese AI, protection of confidential and personal data, and human oversight.
- Geopolitical & counterparty risk – regional instability, shell companies and sudden regulatory changes.
Each Desk is required to detect and report risk indicators, while Tokyo HQ provides unified standards, tools and final decisions.
AML and Sanctions Risk
AML and sanctions risk is treated as the most critical area of Group risk management. ASIACOM applies a strict prevention policy:
High-risk countries – strict exclusion
The Group strictly excludes any business involving North Korea, Iran, and any jurisdiction designated as high-risk by banks, governments, OFAC, the UN, FATF or similar authorities. There are no exceptions, including indirect or third-country routed transactions.
Prohibited cargo and activities
The Group does not handle weapons, illegal drugs, CITES-restricted wildlife, smuggling-related goods, or any cargo that violates international or local law. Such goods are categorically excluded from all ASIACOM operations.
Suspicious commercial practices
ASIACOM prohibits sham or fictitious transactions, documentation mismatches, unexplained payment routes, third-country routing designed to obscure origin or destination, split payments without a clear business reason, and any other structure that may trigger AML concerns.
Risk Management System and Roles
The Group Risk Management System (RMS) operates under the leadership of Tokyo HQ and defines the roles of each Desk:
- Tokyo HQ (Japan Desk) – central risk control center, setting standards, reviewing high-risk cases, leading AML audits and updating the RMS.
- Hong Kong Desk – frontline execution, first-level detection of unusual transactions, documentation inconsistencies and customer risks, with immediate escalation to Tokyo HQ.
- Taiwan Desk – market intelligence and partner verification for Taiwan-related business, reporting geopolitical and counterparty developments to Tokyo HQ.
- Philippine Desk – local communication and support for Philippine-related business, including early warning of regulatory or operational issues.
The Group AI assistant “Ive” is used to support document checks and anomaly detection, but final risk decisions are always made by human management at Tokyo HQ.
Escalation and Continuous Monitoring
All Desks must immediately escalate to Tokyo HQ any case involving:
- High-risk countries or counterparties
- Suspicious or unusual transaction structures
- Inconsistent or altered documents
- Unusual payment routes or banks
- Sensitive or controlled goods
- Regulatory inquiries or warnings
- Cybersecurity or data incidents
Tokyo HQ performs AML-focused audits, updates sanctions screening rules, reviews counterparties on a periodic basis, and convenes regular risk review meetings. The Group Risk Management framework is reviewed at least annually and updated as international AML and AI regulations evolve.