Tokyo HQ – Legal & Policy Overview
Updated: 2025-11-29
This page provides the group-level legal and policy baseline issued by Tokyo HQ (Japan Desk). It explains how we organise governance, risk management, compliance (including AML), privacy and AI governance across the ASIACOM Group.
The legal / policy pages of the Hong Kong, Taiwan and Philippine desks are designed to link back to this overview and then add local-law supplements on each local site, and then confirm any country-specific additions at local level.
Each section below is a short summary. Detailed explanations are provided on dedicated pages linked from this overview.
Talk with Our AI Assistant “Ive”
Under the Tokyo HQ framework, the Japan Desk operates two AI-based tools centered around Ive. These tools help banks, regulators, and major partners understand our structure and policies, while also supporting daily work at each Desk.
1. AI Full-Text Search (Red Panel)
Searches ASIACOM’s JP / HK / TW / PH websites at the document level.
Useful for locating official pages, policies, governance and risk information,
and other group-wide references.
2. Corporate AI Assistant “Ive” (Blue Panel)
Provides corporate-level Q&A about our group structure, trading framework,
Desk functions, governance and compliance framework, and
operating / holiday schedules for each Desk.
Ive operates 24/7 in English and Traditional Chinese.
For a more detailed explanation of why we develop and operate AI in-house at Tokyo HQ, and how Ive is positioned inside ASIACOM Group, please see “Our AI Systems & Ive” .
This interface allows you to ask our corporate AI assistant Ive questions about the ASIACOM Group. Ive is connected directly to Tokyo HQ’s internal AI systems and can provide up-to-date information on all four Desks (JP / HK / TW / PH), including company profiles, governance and compliance framework, trading framework, and Desk operating / holiday schedules.
All responses are generated using our official websites and an internally maintained, compliance-oriented corporate knowledge base. Because Ive runs on ASIACOM’s own AI platform, it can provide more accurate, consistent, and context-aware answers than a generic, keyword-only chatbot.
For matters requiring case-specific verification or formal review, Ive will guide you to the appropriate Desk or Tokyo HQ for manual assistance.
1. Group Structure and Roles
The ASIACOM Group separates front-line commercial operations from centralised oversight and AI functions. Hong Kong serves as the frontline commercial hub for trading activities, while Tokyo HQ acts as the AI, documentation and governance center. Taiwan Desk and Philippine Desk operate as regional satellites under the Japan Desk.
Within this structure, Tokyo HQ is responsible for:
- Group-wide policies for governance, risk management and compliance
- Group-level AML and sanctions awareness standards
- AI governance and system configuration for the Group
- Common documentation standards for banks, regulators and partners
General information on our organisation and desks can be found here:
2. Group Governance Framework (Tokyo HQ)
Governance at the ASIACOM Group level is led by the Japan entity and coordinated through Tokyo HQ. The objective is to keep decision-making transparent, documented and proportionate to our business size and risk profile, while showing clearly that the Group is managed under a Japan-based framework.
Key elements of our governance approach include:
- Clear allocation of roles between Hong Kong (frontline hub) and Tokyo HQ (governance and AI)
- Written internal rules for important processes (contract approvals, counterparty checks, use of AI)
- Regular review of policies when business scope or regulations change
- Alignment between group policies and local-law supplements on each Desk website
The full Group Governance Policy is available here: Corporate Governance (Group).
3. Group Risk Management Approach
Our risk management approach reflects our role as a trading group with a focus on resources, energy-related products and industrial materials. Tokyo HQ works together with Hong Kong, Taiwan and Philippine desks to identify and monitor key risk categories, including those linked to compliance and AML.
Typical risk areas include:
- Market and price risk related to underlying products and projects
- Counterparty and country risk in cross-border transactions
- Operational risk in documentation, logistics and internal processes
- Technology and AI-related risk, including misuse of tools or data
The Group Risk Management Policy provides more detail: Risk Management (Group).
4. Group Compliance and AML Principles
ASIACOM aims to comply with laws and regulations in each country where we operate. Tokyo HQ sets Group-wide compliance standards, while each Desk implements them in line with local law. A central focus is our AML and sanctions stance, which is especially important for banking relationships.
At Group level, we commit to the following key principles:
-
No high-risk or comprehensively sanctioned countries / regions
We do not engage in trade with countries or regions that are subject to comprehensive sanctions or designated as high-risk by our banks (for example, North Korea, Iran and similar jurisdictions), unless a transaction is clearly permitted and has been pre-cleared with our financial institutions. -
No illegal or clearly inappropriate cargo
We do not handle weapons, illegal drugs, or cargo that amounts to smuggling or breaches of international conventions such as the Washington Convention (CITES). -
No fictitious or suspicious trade / settlement patterns
We do not participate in fictitious trade, circular money flows, or any settlement patterns that could reasonably be viewed as money laundering or attempted AML evasion.
These pillars are applied both to trade-related compliance and AI-related operations. Further details are summarised on: Compliance (Group – Trade & AI).
5. AI Governance and Data Handling
All core AI systems used within the ASIACOM Group are operated under a unified framework defined by Tokyo HQ. This includes the Ive assistant, FAQ and trade-terms tools, and other internal support systems used for drafting or reviewing documents.
AI is used to support human judgement, not to replace it. In particular, final decisions and external communication in high-risk areas (AML / sanctions, contracts, communication with regulators and banks) are always made by human staff.
Key AI governance points include:
- Use only of AI services approved by Tokyo HQ (non-Chinese AI providers)
- “Human-in-the-loop” review before using AI outputs in official documents
- Careful handling of personal and confidential data fed into AI systems
- Logging and monitoring of AI usage to detect misuse or policy breaches
The dedicated AI Governance Standard is available here:
AI Governance (Group).
A broader explanation of our AI systems and Ive assistant is provided on:
AI Systems & Ive.
For privacy and personal data handling, please refer to: Privacy Policy.
6. Sustainability and Broader Responsibility
In addition to financial and legal aspects, we also consider environmental and social factors connected to our activities, especially in resource- and energy- related areas. This affects how we select partners, structure transactions and communicate with stakeholders.
Our current thinking and basic commitments are summarised here: Sustainability.
7. How to Use This Page and Contact Point
This page is designed as the single legal and policy gateway for the ASIACOM Group. Local legal pages for Hong Kong, Taiwan and Philippine desks point here as the Group baseline, and then add their own local-law explanations.
In practice:
- For an overview of the Japan Desk and daily operations: see the Tokyo HQ overview page.
- For detailed group-level policies: consult the specific pages linked above (Governance, Risk Management, Compliance, AI Governance, Privacy, Sustainability).
- For formal confirmations, additional documents or questions from banks, regulators or professional advisers: please contact the Japan Desk using the form below.
Contact for formal inquiries: Contact – Japan Desk