Anti-Money Laundering (AML) Policy

Tide Table Logistics Ltd

Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to establish a robust and proactive framework that protects Tide Table Logistics Ltd from being misused, whether knowingly or unknowingly, in the facilitation of money laundering, terrorist financing, or any other financial crime. Given the nature of our operations — spanning international commodity brokerage, precious mineral sourcing, marine workforce recruitment, and chandlery services — the company regularly engages in cross-border transactions, foreign currency exchanges, and high-value commodity trades that may attract the attention of criminal entities.

This policy aims to uphold the company’s legal, ethical, and professional obligations under UK anti-money laundering legislation, Ghanaian financial regulations, and international standards set by bodies such as the Financial Action Task Force (FATF). By implementing rigorous identification, verification, monitoring, and reporting mechanisms, Tide Table Logistics Ltd seeks to:

Deter and detect attempts to introduce illicit funds into the financial system via our services by applying rigorous controls at every stage of the commercial lifecycle — from initial client onboarding and transaction structuring, to final delivery, payment settlement, and documentation. Tide Table Logistics Ltd is committed to preventing its platform, personnel, and global trade infrastructure from being exploited by individuals or entities seeking to legitimize proceeds from criminal activities, including drug trafficking, corruption, tax evasion, smuggling, fraud, and terrorism. Through vigilant screening, ongoing monitoring, and active cooperation with financial intelligence units and law enforcement, the company aims to disrupt the financial mechanisms that enable such crimes to flourish.
Ensure all business relationships are established with reputable and legitimate entities by conducting thorough due diligence on every prospective client, supplier, intermediary, or partner before entering into any contractual arrangement or financial transaction. This includes verifying corporate registration, beneficial ownership, trading history, sanctions status, and legal standing in accordance with applicable UK and Ghanaian regulations. Tide Table Logistics Ltd does not engage with anonymous entities, shell companies lacking transparency, or organizations operating in violation of international laws. By upholding stringent verification standards, the company reduces its exposure to reputational risk, legal liability, and the infiltration of criminal networks.
Maintain the company’s reputation for integrity, transparency, and legal compliance in all jurisdictions of operation by embedding anti-money laundering principles into the core of Tide Table Logistics Ltd’s strategic, operational, and transactional practices. As an international entity conducting high-value trades and maritime services across the UK, Ghana, and other global markets, the company recognizes that its reputation is both a competitive advantage and a regulatory obligation. By adhering strictly to local and international AML laws, promoting ethical conduct at all levels, and demonstrating a proactive stance toward compliance, the company reinforces trust among clients, regulators, investors, and institutional partners.
Protect our clients, partners, and employees from the legal and reputational risks associated with financial crime by ensuring that all business activities conducted through Tide Table Logistics Ltd are safeguarded against illicit interference. This includes implementing robust safeguards that prevent stakeholders from being inadvertently involved in schemes related to money laundering, terrorist financing, fraud, or corruption. By enforcing strict compliance protocols, providing AML training, and maintaining transparent processes, the company creates a secure environment where commercial and operational decisions are made with confidence, backed by verifiable legality and ethical integrity.
Contribute to the global effort against terrorism, drug trafficking, corruption, fraud, and organized crime by reporting suspicious activities in a timely and accurate manner. Tide Table Logistics Ltd recognizes that its operations, particularly in international commodity trading and maritime logistics, may intersect with industries and jurisdictions vulnerable to exploitation by criminal networks. As part of its duty to uphold global security and financial integrity, the company is committed to promptly identifying, documenting, and reporting any transactions, behaviors, or client relationships that raise suspicion. These reports are submitted in compliance with legal obligations to the UK’s National Crime Agency (NCA) and Ghana’s Financial Intelligence Centre (FIC). Through accurate and timely reporting, the company helps disrupt illicit financial flows, protect international markets, and support coordinated global action against transnational crime.

In doing so, Tide Table Logistics Ltd not only safeguards its own business interests, operations, and reputation, but also reinforces global confidence in fair and ethical trade practices. By taking an active role in the prevention of financial crime—particularly in sectors such as extractives, petroleum, and maritime logistics, which are historically susceptible to corruption, smuggling, and illicit finance—the company contributes to a more transparent, secure, and accountable international marketplace. This commitment enhances trust among regulators, investors, clients, and institutional partners, while positioning Tide Table Logistics Ltd as a responsible and compliant leader in its field.

Scope

This Anti-Money Laundering (AML) Policy applies comprehensively to all individuals, departments, and entities connected to the operations of Tide Table Logistics Ltd, irrespective of their geographic location, employment status, or contractual relationship with the company. It encompasses full compliance responsibilities across every level of the organization and its business functions, ensuring a consistent and unified approach to AML risk mitigation.

Permanent employees working in the UK, Ghana, or remotely, who are directly or indirectly involved in critical business functions such as commodity trading, documentation processing, financial management, procurement, compliance monitoring, and client onboarding. These individuals are required to strictly adhere to this AML Policy, apply due diligence measures, and report any suspicious activities or anomalies encountered in the course of their duties.
Contractors and consultants engaged by the company to support any part of the transaction lifecycle—including but not limited to advisory, inspection, logistics, and legal support roles—are also subject to this AML Policy. They must comply with all relevant due diligence procedures, maintain confidentiality, and promptly report any suspicious or unusual activities detected during their engagement with Tide Table Logistics Ltd. This ensures that all external personnel involved in critical processes uphold the company’s commitment to transparency and legal compliance.
Agents and facilitators who serve as intermediaries in buyer-seller negotiations, mineral sourcing, or maritime recruitment activities fall within the ambit of this AML Policy. Given their critical role in connecting parties and facilitating transactions, these intermediaries must adhere strictly to all due diligence, verification, and compliance procedures mandated by Tide Table Logistics Ltd. This includes the obligation to maintain accurate records, disclose any conflicts of interest, and immediately escalate suspicious behavior or irregularities to the company’s compliance team. By incorporating agents and facilitators under this policy’s scope, Tide Table Logistics Ltd mitigates risks associated with indirect dealings and ensures full transparency throughout the commercial chain.
Third-party service providers, including banks, freight forwarders, SGS/inspection agencies, and marine chandlers, when acting on Tide Table Logistics Ltd’s behalf, are subject to this AML Policy. These external entities play a crucial role in supporting the company’s commodity brokerage, logistics, inspection, and vessel provisioning activities. As such, they must comply with all relevant anti-money laundering and compliance requirements, including proper client identification, transaction monitoring, and reporting obligations. Tide Table Logistics Ltd requires these providers to maintain transparent records, cooperate fully with any investigations, and ensure that their services do not facilitate illicit financial flows or the circumvention of regulatory controls.
Joint venture partners, exporters, and buyers, when entering into commercial relationships with Tide Table Logistics Ltd that involve shared exposure to financial transactions or supply chains dealing with high-value commodities, are encompassed within this AML Policy. Such partners must adhere to the company’s due diligence and compliance standards to ensure transparency and legality across all transactions. This includes cooperating with information requests, submitting necessary documentation, and participating in risk assessments. By extending the scope to these critical stakeholders, Tide Table Logistics Ltd safeguards its operations from risks associated with money laundering, fraud, and illicit trade, while fostering trust and accountability within its broader commercial ecosystem.

This policy governs all relevant activities across the following core business areas of Tide Table Logistics Ltd, ensuring comprehensive anti-money laundering controls are integrated throughout the company’s operations:

Commodity Trading: This includes all activities related to the sale, purchase, brokerage, and facilitation of international transactions involving crude oil (such as Bonny Light Crude), refined petroleum products including Automotive Gas Oil (AGO), Jet A1 aviation fuel, Liquefied Natural Gas (LNG), and precious minerals such as gold, copper, silver, and rough diamonds. Given the high value and cross-border nature of these commodities, Tide Table Logistics Ltd applies stringent due diligence, transaction monitoring, and documentation controls to mitigate the risk of money laundering, fraud, and the financing of illicit activities within this sector.
Client Onboarding & Trade Verification: This encompasses all procedures related to the identification, verification, and ongoing due diligence of clients, counterparties, suppliers, and mandate holders. Particular emphasis is placed on transactions involving Letters of Intent (LOIs), Soft Corporate Offers (SCOs), and Sales & Purchase Agreements (SPAs), where accurate verification is critical to prevent fraudulent activities and ensure legitimate trade relationships. Tide Table Logistics Ltd employs comprehensive Know Your Customer (KYC) protocols, enhanced due diligence (EDD) for higher-risk parties, and rigorous document authentication to validate the credibility, legal standing, and compliance of all trading partners before transaction execution.
Document Processing: This covers all activities related to the creation, validation, secure handling, and archiving of sensitive commercial documents integral to the company’s trading operations. Key documents include Bills of Lading (B/L), Certificates of Origin (COO), Marine Insurance Certificates, and other export/import paperwork. Tide Table Logistics Ltd implements strict controls to ensure the authenticity, accuracy, and compliance of these documents with international trade regulations and anti-fraud measures. Proper document management safeguards against forgery, misrepresentation, and transactional irregularities that could facilitate money laundering or other financial crimes.
Financial Transactions: This section encompasses all monetary activities facilitated or managed by Tide Table Logistics Ltd, including payments, escrow arrangements, issuance and management of Letters of Credit (LCs), commission disbursements, and international remittances. Given the complexity and high value of transactions inherent in commodity trading and maritime services, stringent controls are applied to verify the legitimacy of funds, ensure compliance with anti-money laundering regulations, and prevent the misuse of financial channels. All financial processes are subject to continuous monitoring for suspicious patterns, thorough record-keeping, and compliance with jurisdictional financial laws and international standards.

This comprehensive scope ensures that every individual and entity engaged in Tide Table Logistics Ltd’s operations—whether internal staff, contractors, or external partners—is fully aware of their responsibilities and held accountable for preventing financial crime. It reinforces a company-wide culture grounded in ethical conduct, transparency, and risk awareness, thereby safeguarding the integrity of all business activities and promoting compliance with global regulatory standards.

Responsibilities

Ensuring full compliance with anti-money laundering laws, regulations, and ethical standards is a fundamental obligation shared by all personnel at Tide Table Logistics Ltd. However, to guarantee clear accountability and effective implementation of this AML Policy, specific roles within the organization have been designated with distinct responsibilities. These roles ensure a coordinated approach to risk management, compliance monitoring, and reporting, thereby embedding AML controls into the fabric of the company’s operations.

Each designated party is empowered and expected to perform their duties diligently, maintaining vigilance against financial crime risks and fostering a culture of compliance and transparency throughout the organization.

1. Compliance Officer (UK Headquarters)

The Compliance Officer serves as the central authority for all anti-money laundering (AML) oversight, implementation, training, and reporting across Tide Table Logistics Ltd’s global operations. Operating from the UK headquarters, this role is vital in establishing and maintaining a company-wide culture of compliance, ensuring that Tide Table consistently adheres to AML legislation, regulatory expectations, and ethical best practices across all jurisdictions in which it operates.

The Compliance Officer’s primary responsibilities include:

Designing, внедрять и поддерживать AML Policy и связанные с ней внутренние механизмы контроля для обеспечения полного соответствия применимым законам и нормативным актам как в Соединенном Королевстве, так и в Гане. Это включает постоянное соответствие международным лучшим практикам и стандартам, установленным Финансовой группой разработки мер по борьбе с отмыванием денег (FATF). Офицер по соблюдению нормативных требований должен обеспечить, чтобы политика оставалась актуальной и эффективной в решении возникающих рисков, типологий и изменений в законодательстве. Внутренние механизмы контроля должны быть адаптированы к характеру операций Tide Table Logistics Ltd, масштабируемыми для различных юрисдикций и интегрированными в повседневные рабочие процессы для активного предотвращения и выявления отмывания денег и связанных финансовых преступлений.
Acting as the designated point of contact for law enforcement agencies, regulators, and financial intelligence units (FIUs)—including, but not limited to, the UK’s National Crime Agency (NCA) and Ghana’s Financial Intelligence Centre (FIC). The Compliance Officer is responsible for managing all formal communications and disclosures related to anti-money laundering matters. This includes responding to regulatory inquiries, coordinating audits or investigations, and ensuring timely submission of Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs). The Compliance Officer must also maintain open, cooperative, and transparent relationships with competent authorities, ensuring that the company’s reporting obligations are fulfilled with accuracy, confidentiality, and urgency.
Overseeing and managing the end-to-end client and counterparty due diligence process, ensuring that all individuals and entities engaged in business with Tide Table Logistics Ltd are subject to appropriate levels of scrutiny based on risk. This includes conducting initial Know Your Customer (KYC) checks, verifying identities and beneficial ownership structures, assessing geographic and transactional risk, and screening against international sanctions lists. For clients, partners, or transactions deemed high-risk—due to jurisdiction, volume, or complexity—the Compliance Officer must ensure that Enhanced Due Diligence (EDD) procedures are rigorously applied. This involves gathering additional information, obtaining senior management approval, and implementing ongoing monitoring measures. The goal is to ensure that the company does not enter or remain in business relationships that pose an undue risk of facilitating money laundering, terrorist financing, or other illicit financial activity.
Monitoring transactional activity and identifying unusual or suspicious patterns, in close collaboration with the operations and finance teams. The Compliance Officer is responsible for ensuring that all financial and commodity-related transactions processed through Tide Table Logistics Ltd are systematically reviewed for potential red flags. This includes analyzing payment behaviors, trade documentation, counterparties’ business justifications, geographic risk factors, and transaction structures that may be inconsistent with the client’s known profile or legitimate trade activity. Using both manual reviews and automated tools where applicable, the Compliance Officer must promptly investigate anomalies, determine whether further inquiry is warranted, and initiate internal escalation protocols when needed. This proactive oversight is critical to the early detection of attempted money laundering or other financial misconduct.
Receiving, assessing, and—when necessary—filing Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) in accordance with applicable legal requirements, regulatory timeframes, and strict confidentiality protocols. The Compliance Officer is responsible for maintaining secure channels through which employees, agents, or third parties can report concerns about suspicious or potentially unlawful activity. Upon receipt of such concerns, the Compliance Officer must conduct an impartial, confidential assessment to determine whether the activity meets the threshold for suspicion under relevant laws, such as the UK Proceeds of Crime Act 2002 or Ghana’s Anti-Money Laundering Act, 2020. If warranted, the Compliance Officer is tasked with preparing and submitting formal SARs or STRs to the UK’s National Crime Agency (NCA), Ghana’s Financial Intelligence Centre (FIC), or any other relevant authority. All filings must preserve confidentiality, protect the identity of the reporting party, and be accurately documented for audit and follow-up purposes.
Coordinating and delivering AML training to employees, contractors, agents, and key third-party partners to promote consistent awareness of money laundering risks, legal obligations, and individual responsibilities. The Compliance Officer must ensure that all relevant personnel—particularly those involved in high-risk functions such as commodity trading, finance, documentation, client onboarding, and recruitment—receive tailored training appropriate to their role and exposure. Training programs should cover key topics including the identification of suspicious behavior, the reporting process for SARs, obligations under UK and Ghanaian AML laws, and updates to internal policies or global regulatory frameworks (e.g., FATF recommendations). Training should be conducted during onboarding and refreshed regularly—at least annually—along with ad-hoc sessions when significant regulatory changes occur. Attendance must be recorded, and the effectiveness of training programs should be evaluated periodically through testing, surveys, or compliance audits.
Conducting periodic reviews and audits of AML practices to ensure policy effectiveness and to identify areas requiring improvement or remediation. The Compliance Officer is responsible for leading scheduled and risk-based internal assessments of Tide Table Logistics Ltd’s AML framework, including its policies, procedures, and operational controls. These reviews aim to evaluate whether the company’s AML measures remain adequate, responsive to evolving threats, and aligned with legal and regulatory expectations. The audits must include analysis of due diligence files, transaction monitoring records, training logs, SAR handling procedures, and communication with regulators. Any deficiencies identified must be documented, prioritized, and addressed through a formal remediation plan, with oversight and sign-off from senior management. Where necessary, external audits or third-party reviews may be commissioned to ensure objectivity and thoroughness.
Keeping senior management and the Board of Directors informed on AML risk exposure, emerging trends, and mitigation strategies, including submitting periodic compliance reports. The Compliance Officer must provide timely, clear, and comprehensive updates to the company’s leadership to ensure that decision-makers maintain full visibility of the AML risk landscape and the effectiveness of controls. These reports should include summaries of risk assessments, findings from audits and investigations, statistics on client onboarding and transaction monitoring, details of any suspicious activity reports filed, and updates on regulatory changes affecting the business. By delivering actionable insights and recommendations, the Compliance Officer supports the Board and senior executives in making informed decisions about resource allocation, policy adjustments, and strategic risk management, thereby strengthening Tide Table Logistics Ltd’s overall compliance posture.
Ensuring that all AML documentation, including Know Your Customer (KYC) files, due diligence records, and compliance registers, is securely maintained and retained for at least five (5) years as required by applicable laws and regulations. The Compliance Officer must establish and enforce secure document management systems that protect sensitive client and transaction information from unauthorized access, loss, or tampering. This includes implementing data encryption, access controls, and regular backups. Retention schedules should comply with both UK and Ghanaian legislative requirements, ensuring records are preserved for the statutory period following the completion of transactions or termination of business relationships. Proper documentation supports audit trails, regulatory inspections, and potential investigations, reinforcing the company’s commitment to transparency and accountability.

2. Operations Team (Ghana and UK Divisions)

The Operations Team serves as a critical frontline unit responsible for the practical enforcement of Tide Table Logistics Ltd’s Anti-Money Laundering (AML) policies and procedures in both Ghana and the UK. Their role encompasses the meticulous execution of due diligence, vigilant transaction monitoring, and secure documentation management to safeguard the company from financial crime risks across its international operations.

Key responsibilities include:

Conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) where applicable: The Operations Team must rigorously collect and verify all necessary identification documents such as passports, business registrations, licenses, certificates of origin, and proof of funds or product legitimacy. For clients or transactions presenting elevated risks—such as those involving politically exposed persons (PEPs), high-value commodity trades, or operations in high-risk jurisdictions—the team must apply Enhanced Due Diligence protocols. This includes obtaining deeper insights into the client’s business activities, source of funds, and beneficial ownership structures to prevent illicit actors from infiltrating the supply chain.
Monitoring transactions for inconsistencies, red flags, or anomalies: The team is tasked with scrutinizing trade and financial transactions for warning signs indicative of potential money laundering or fraud. Examples include but are not limited to round-dollar payments, involvement of offshore accounts, unusually complex ownership chains, sudden changes in trading behavior, or discrepancies between declared cargo and shipment documentation. Such observations must be systematically flagged and documented.
Escalating suspicious behavior or documentation to the Compliance Officer: When the Operations Team identifies questionable activities or documentation inconsistencies, they are required to promptly report these concerns to the Compliance Officer for thorough investigation. This escalation is vital to ensuring that all suspicious activities are evaluated by AML specialists and, if necessary, formally reported to regulatory authorities.
Maintaining accurate and secure records: The team must ensure that all documentation related to client onboarding, trade transactions, and compliance checks is kept accurate, complete, and securely stored for a minimum retention period of five years, as mandated by AML laws in both the UK and Ghana. This archival practice supports audit readiness, regulatory inspections, and internal review processes.
Collaborating with external validators: The Operations Team works closely with third-party organizations such as SGS inspection agencies, financial institutions, shipping companies, and other supply chain partners to verify the authenticity and integrity of physical shipments, payment flows, and compliance documentation. This collaboration ensures a cohesive and transparent trade environment that minimizes exposure to illicit activities.

3. Directors (UK & Ghana Corporate Entities)

The Board of Directors holds the ultimate responsibility for governing Tide Table Logistics Ltd’s commitment to Anti-Money Laundering (AML) compliance and fostering a corporate culture rooted in integrity and transparency. Their leadership sets the tone at the top, signaling to all employees, partners, and stakeholders the company’s dedication to lawful and ethical business conduct.

Key responsibilities include:

Providing strategic oversight of the company’s AML framework: Directors must ensure that Tide Table Logistics Ltd’s AML policies, procedures, and controls are comprehensive, up-to-date, and effectively implemented. This involves allocating adequate resources, such as qualified personnel, technology, and training programs, to maintain robust compliance standards. Directors are also responsible for endorsing and supporting initiatives aimed at continuously enhancing the AML program in line with evolving legal and regulatory landscapes.
Reviewing regular AML reports from the Compliance Officer: The Board must diligently examine periodic reports submitted by the Compliance Officer, which detail risk assessments, audit findings, suspicious activity investigations, and regulatory developments. Directors are expected to engage actively with this information, provide guidance on remediation actions, and ensure that material issues are addressed promptly to mitigate compliance risks.
Approving high-risk relationships or transactions: For client relationships or transactions that exceed predefined risk thresholds—due to factors such as high-value commodity trades, involvement of politically exposed persons (PEPs), or operations in high-risk jurisdictions—the Directors are responsible for reviewing and approving these cases following the company’s internal escalation and risk management procedures. This governance step ensures that high-risk exposures receive thorough scrutiny and informed decision-making at the highest level.
Ensuring compliance with AML requirements of the UK and Ghana: Directors must maintain an in-depth understanding of relevant legislation, including the UK Money Laundering Regulations 2017, Proceeds of Crime Act 2002, and Ghana’s Anti-Money Laundering Act, 2020. They are accountable for steering the company’s adherence to these laws, ensuring all business activities comply fully with legal mandates to avoid regulatory sanctions and reputational damage.
Embedding a culture of transparency, accountability, and legal compliance: The Board is instrumental in cultivating an organizational culture that prioritizes ethical conduct, openness, and accountability. This culture must permeate all business units, partnerships, and international engagements, reinforcing the company’s stance against financial crime and promoting fair trade practices across all jurisdictions where Tide Table Logistics Ltd operates.

Procedures

To effectively mitigate the risk of financial crime, Tide Table Logistics Ltd enforces a clear, step-by-step process for client verification, transaction monitoring, escalation, and documentation. These procedures are rigorously applied across all departments involved in commodity trading, marine services, financial operations, and third-party facilitation to ensure robust compliance with anti-money laundering regulations.

1. Client Identification and Verification (KYC)

Before entering into any business relationship, Tide Table Logistics Ltd undertakes a thorough and methodical Know Your Customer (KYC) process to verify the identity, legitimacy, and risk profile of all clients, intermediaries, suppliers, and counterparties. This critical step helps prevent the misuse of the company’s services for money laundering, terrorist financing, or other financial crimes.

The KYC process includes the following detailed measures:

Individual Clients:

Collection of Valid Government-Issued Photo Identification: Tide Table Logistics Ltd requires original or certified copies of government-issued photo identification documents, such as passports or driver’s licenses, to confirm the client’s legal identity. These documents must be current and unexpired.
Proof of Address: To verify residence, clients must provide recent proof of address documents, such as utility bills, bank statements, or tax correspondence, dated within the last 90 days. This helps confirm the client’s geographic location and reduces the risk of false identities.
Source of Funds or Wealth Verification (where applicable): For transactions of significant value or clients from higher-risk jurisdictions, the company requests documented declarations detailing the origin of funds or overall wealth. This may include bank statements, salary slips, business income reports, or inheritance documents. This step is essential to ensure funds used in transactions are legitimate and not derived from illicit activities.

Corporate Clients:

Company Registration Documentation: Tide Table Logistics Ltd obtains certified copies of the Certificate of Incorporation, Articles of Association, and any Corporate Resolutions authorizing the transaction or business relationship. These documents establish the legal existence of the corporate entity and its governance structure.
Verification of Company Registration: The company’s registration details are cross-checked against the relevant national government registrar, chamber of commerce, or corporate registry to confirm authenticity and good standing. This reduces the risk of engaging with shell companies or fraudulent entities.
Identification of Beneficial Owners and Key Personnel: The identities of beneficial owners (those who ultimately own or control the company), directors, and authorized signatories must be documented. This includes collecting valid government-issued IDs and verifying their legitimacy. Identifying these individuals is critical to uncover hidden ownership and control structures often exploited for financial crime.
Sanctions and PEP Screening: All corporate clients and their associated beneficial owners are screened against international sanctions lists, including those maintained by the Office of Foreign Assets Control (OFAC), United Nations (UN), European Union (EU), and other relevant authorities. Additionally, clients are checked against databases of Politically Exposed Persons (PEPs) to identify any heightened risk related to corruption or bribery. Positive hits trigger enhanced due diligence measures and internal review.

Completion of Verification:

Verification and due diligence must be fully completed and documented before Tide Table Logistics Ltd proceeds with any commercial transaction, trade facilitation, or sharing of sensitive documentation. No business activities are to be conducted with unverified clients or counterparties to uphold compliance and risk management standards.

2. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) represents a critical escalation in the company’s anti-money laundering efforts, specifically designed to address situations and relationships identified as posing a higher risk of money laundering, terrorist financing, fraud, or other illicit activities. Given the complex and high-value nature of Tide Table Logistics Ltd’s operations—spanning international commodity brokerage, precious minerals, and maritime services—rigorous EDD procedures are essential to protect the company’s integrity and regulatory compliance.

When to Apply EDD

EDD measures must be applied in the following circumstances:

Clients or Counterparties from High-Risk Jurisdictions: Any client or business relationship originating from countries or regions designated as high-risk or non-cooperative by the Financial Action Task Force (FATF), the UK’s HM Treasury, Ghana’s Financial Intelligence Centre (FIC), or other regulatory authorities must undergo heightened scrutiny. This includes jurisdictions with weak AML laws, significant corruption, terrorism financing concerns, or sanctions.
High-Value or Complex Transactions: Transactions exceeding thresholds of £100,000 or $125,000 warrant additional checks, especially when funds are routed through multiple financial institutions, offshore companies, or involve complex ownership or payment structures designed to obscure the source or destination of funds.
Opaque Ownership and Control Structures: Clients with complicated or unclear ownership arrangements, such as layered subsidiaries, trusts, nominee shareholders, or entities with limited publicly available information, must be subject to EDD. Such structures often signal attempts to conceal beneficial ownership or illicit activities.
Unusual or Suspicious Trade Terms: Requests involving atypical commercial conditions—such as payments by third parties unrelated to the transaction, use of cryptocurrencies or other non-traditional payment methods, urgent shipping instructions with minimal supporting documents, or changes to previously agreed terms—trigger mandatory EDD procedures.

Specific EDD Actions

To thoroughly assess and mitigate elevated risks, the following enhanced due diligence steps are mandatory:

Collection of Additional Documentation: Tide Table Logistics Ltd requires supplementary documentation beyond standard KYC. This includes audited financial statements, detailed trade histories, business plans, contracts, letters of credit, tax filings, or proof of ongoing business activity to verify legitimacy and operational stability.
Direct Verification via Video Calls: Personal verification of key decision-makers, beneficial owners, or authorized representatives is conducted through live video interviews. This measure helps confirm identity, assess credibility, and clarify any discrepancies found during document review.
Board-Level Approval: Before initiating or continuing a relationship flagged for EDD, the case must be escalated to the company’s Board of Directors or designated senior management for formal approval. This governance step ensures that the highest levels of the company are informed and that risk acceptance is deliberate and documented.
Engagement of External Experts: When internal resources and expertise are insufficient to fully assess the risk, Tide Table Logistics Ltd may engage external compliance consultants, forensic investigators, or legal advisors. These specialists provide independent verification, background checks, or investigation into suspicious activities.

Documentation and Record-Keeping

All findings, assessments, and decisions related to Enhanced Due Diligence must be meticulously documented and securely stored in accordance with legal retention requirements. This documentation includes:

Copies of all additional documents collected.
Records of video call verifications, including participant identities and summaries.
Minutes or resolutions reflecting board-level approvals.
Reports and correspondence with any external consultants engaged.

Maintaining comprehensive EDD records not only ensures regulatory compliance but also enables effective audits, investigations, and internal reviews if suspicious activity arises in the future.

By rigorously applying these EDD procedures, Tide Table Logistics Ltd significantly strengthens its defenses against financial crime, protects its reputation, and fosters trustworthy business relationships aligned with international best practices.

3. Transaction Monitoring and Red Flag Identification

Effective transaction monitoring is a cornerstone of Tide Table Logistics Ltd’s commitment to preventing financial crime, including money laundering, terrorist financing, fraud, and other illicit activities. Given the complexity of international commodity brokerage and maritime services, ongoing vigilance throughout the lifecycle of every financial and commercial transaction is essential.

Continuous Monitoring of Transactions

All transactions—whether payments, shipments, contractual agreements, or document exchanges—are subject to continuous scrutiny to detect any anomalies or irregularities that may signal suspicious activity. This includes:

Financial Transactions: Payments made or received via bank transfers, letters of credit, escrow arrangements, or alternative payment methods.
Commercial Operations: Shipment records, bills of lading (B/L), certificates of origin, cargo manifests, and contracts.
Third-Party Interactions: Activities involving intermediaries such as agents, freight forwarders, inspection companies, or marine chandlers.

The goal is to ensure that all transactions align with the known business profile of clients and counterparties, and that no unusual patterns emerge that could indicate attempts to disguise illicit activity.

Examples of Common Red Flags

Tide Table Logistics Ltd’s team is trained to identify key indicators of potential financial crime. Some critical red flags include:

Overpayments or Under-Invoicing: When a client sends payments exceeding the invoiced amount, followed by requests for refunds or fund reversals, it may suggest layering or integration phases of money laundering.
Rapid Fund Movement Across Multiple Jurisdictions: Transfers that quickly move funds through unrelated third parties, offshore banks, or high-risk countries with no clear business rationale can be indicative of money laundering or sanction evasion.
Use of Shell Companies or Nominees: Entities with no verifiable operational history, no physical offices, or nominee directors are often vehicles for hiding the true beneficial owners or conducting fraudulent transactions.
Inconsistent or Missing Trade Documentation: Discrepancies such as bills of lading that do not correspond with port arrival/departure data, altered shipping documents, or missing certificates of origin may signal document fraud or smuggling.
Client Evasion or Refusal to Provide KYC: When clients resist or delay submission of identification documents, become vague or evasive when questioned, or provide inconsistent information, it raises a significant compliance concern.

Monitoring Methods

Manual Review: Trained personnel from the Operations and Compliance teams systematically review transaction details, supporting documents, client profiles, and payment trails for unusual activity.
Use of Transaction Analytics Tools: Where feasible, automated software and analytics platforms are employed to flag suspicious patterns such as frequent round-dollar payments, unusual transaction volumes, or activity inconsistent with typical client behavior.

Escalation Procedures

Upon detection of any suspicious or anomalous activity, the following steps are immediately taken:

Documentation: All relevant transaction details and observed red flags are recorded clearly and comprehensively.
Immediate Reporting: The matter is escalated without delay to the designated Compliance Officer for further investigation.
Initial Assessment: The Compliance Officer reviews the transaction and any supporting evidence to determine if a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) needs to be filed with the appropriate authorities, such as the UK’s National Crime Agency (NCA) or Ghana’s Financial Intelligence Centre (FIC).
Follow-up Actions: Depending on the outcome, the company may halt transactions, suspend client onboarding, or seek additional verification before proceeding.

By maintaining vigilant, real-time monitoring combined with clear escalation protocols, Tide Table Logistics Ltd actively mitigates the risk of financial crime, ensuring compliance with regulatory requirements and safeguarding the company’s reputation.

4. Suspicious Activity Reporting (SARs)

Suspicious Activity Reporting is a critical element of Tide Table Logistics Ltd’s Anti-Money Laundering framework, serving as the company’s primary mechanism for alerting law enforcement and regulatory bodies about potential financial crimes. Timely and accurate reporting of suspicious transactions not only fulfills legal obligations but also supports global efforts to combat money laundering, terrorist financing, fraud, and other illicit activities.

Internal Reporting by Staff

Any employee, contractor, agent, or partner who reasonably suspects that a transaction, client, or associated activity may be connected to criminal conduct must immediately report the concern to the designated Compliance Officer. This internal reporting obligation includes, but is not limited to:

Suspicion of funds derived from criminal activity.
Clients exhibiting evasive or inconsistent behavior during KYC.
Transactions involving unusually complex or opaque structures.
Requests to circumvent standard compliance procedures.
Any other conduct that deviates markedly from normal business practices.

Prompt reporting ensures that potential issues are addressed before completion of transactions and that the company remains compliant with AML legislation.

Role of the Compliance Officer

Upon receiving an internal report of suspicious activity, the Compliance Officer undertakes a confidential and thorough review process:

Review of Transaction Details: The Compliance Officer examines all relevant documentation, client records, and communication logs to evaluate the legitimacy of the suspicion.
Consultation: Where necessary, the Compliance Officer may consult with senior management, legal advisors, or external compliance experts to assess risks and options.
Decision to Report: If the Compliance Officer concludes that there are reasonable grounds to suspect involvement in money laundering or other financial crime, they will prepare a Suspicious Activity Report (SAR).

Filing Suspicious Activity Reports

The SAR is a formal notification submitted to the appropriate national authority tasked with financial intelligence and crime prevention. Tide Table Logistics Ltd complies with the following jurisdictional requirements:

In the United Kingdom: SARs are submitted to the National Crime Agency (NCA) under the authority of the Proceeds of Crime Act 2002. The NCA’s secure online portal (SAR Online) is used for report submission.
In Ghana: SARs are submitted to the Financial Intelligence Centre (FIC) pursuant to the Anti-Money Laundering Act, 2020, using designated secure channels.

Post-Reporting Actions

Transaction Suspension: Once a SAR has been filed, no further transactions related to the suspicious activity shall proceed until explicit clearance is granted by the relevant authority.
Confidentiality and No Tipping Off: It is a criminal offense under both UK and Ghanaian law to disclose to any client, third party, or unauthorized person that a SAR has been filed or is under consideration. All employees must maintain strict confidentiality to prevent tipping off, which could undermine investigations and expose the company to legal penalties.

Record Keeping

All SARs, associated investigations, and related communications must be documented and securely retained for a minimum of five years to comply with regulatory requirements and facilitate audits or legal reviews.

By rigorously enforcing this Suspicious Activity Reporting procedure, Tide Table Logistics Ltd strengthens its defenses against financial crime, supports law enforcement agencies in their investigative efforts, and upholds its commitment to ethical and compliant business practices worldwide.

5. Record Retention

Maintaining comprehensive, accurate, and secure records is a cornerstone of Tide Table Logistics Ltd’s Anti-Money Laundering (AML) compliance framework. Proper record retention ensures transparency, supports regulatory oversight, facilitates audits, and provides a defensible trail of evidence in the event of investigations or legal inquiries.

Duration of Retention

In alignment with both UK and Ghanaian AML regulations, all records related to customer due diligence, transactions, and suspicious activity reporting must be retained for a minimum period of five (5) years. This retention period begins from either:

The date of completion of the transaction in question, or
The date on which the business relationship with the client or counterparty is formally terminated,

whichever is later.

Types of Records to Retain

Tide Table Logistics Ltd is required to securely retain a broad range of documentation to demonstrate ongoing compliance with AML obligations, including but not limited to:

Know Your Customer (KYC) and Enhanced Due Diligence (EDD) Files: This includes identification documents such as passports, driver’s licenses, proof of address, corporate registration certificates, beneficial ownership details, and records of any enhanced scrutiny conducted on high-risk clients or transactions.
Client Communication Logs: All correspondences—email exchanges, meeting notes, phone call records, and other communications—that relate to client onboarding, due diligence, transaction negotiation, or AML inquiries must be documented and retained.
Transaction Records and Payment Details: Complete records of payments, bank instructions, remittance advices, escrow agreements, and other financial documents linked to each transaction must be preserved to ensure traceability of funds.
Suspicious Activity Reports (SARs) and Investigation Documentation: Copies of all filed SARs, internal investigation notes, decisions made by the Compliance Officer, and correspondence with law enforcement or regulatory bodies must be securely archived.
Contracts, Invoices, and Shipping Documentation: Documents such as Sales & Purchase Agreements (SPAs), Bills of Lading, Certificates of Origin, insurance certificates, and invoices related to each trade or service transaction are essential to corroborate the legitimacy of the commercial activity.

Storage and Security

To protect the integrity and confidentiality of sensitive information, Tide Table Logistics Ltd mandates the following storage standards:

Digital Archives: All electronic records must be stored in encrypted databases or secure document management systems with strong access controls, multi-factor authentication, and routine backups to prevent data loss or unauthorized access.
Physical Files: Where hard copies are maintained, they must be kept in locked, access-controlled environments with restricted entry, monitored by security personnel or systems.
Access Control: Access to AML-related records is strictly limited to authorized personnel, such as the Compliance Officer and designated compliance staff. Employees outside of the compliance function should not have access to these sensitive records unless explicitly approved for legitimate business purposes.

Audit and Compliance

The robust retention of records facilitates:

Regulatory Inspections: Enabling prompt and transparent responses to AML audits or regulatory inquiries by relevant authorities.
Internal Reviews: Supporting periodic internal audits and reviews to verify adherence to the AML Policy and identify opportunities for improvement.
Legal Defense: Providing documented evidence in defense of the company should any allegations of financial crime arise.

By upholding these stringent record retention standards, Tide Table Logistics Ltd not only meets its statutory obligations but also strengthens the overall resilience of its AML controls, contributing to a trustworthy and compliant international business environment.

Compliance

Tide Table Logistics Ltd is fully committed to conducting its operations in strict accordance with both domestic and international anti-money laundering laws, regulatory frameworks, and best-practice standards. This policy is structured to ensure full compliance with the following primary legal instruments:

1. United Kingdom: Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

As a company legally incorporated and actively operating within the United Kingdom, Tide Table Logistics Ltd is fully committed to complying with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (hereafter referred to as “the Regulations”), including all subsequent amendments introduced in 2019 and 2020. These Regulations provide a comprehensive legal framework designed to prevent the misuse of businesses and financial systems for money laundering, terrorist financing, and related financial crimes.

Key Compliance Requirements Under the Regulations

Tide Table Logistics Ltd ensures that all its operations, policies, and procedures reflect the following core mandates of the Regulations:

Risk-Based Due Diligence: The company applies a risk-based approach to customer due diligence (CDD) and transaction monitoring. This means that clients and transactions are assessed according to their inherent risk factors, such as geographic location, business nature, transaction size, and ownership structure. Higher-risk clients and transactions are subject to enhanced due diligence (EDD) measures to ensure that potential money laundering or terrorist financing threats are thoroughly identified and mitigated.
Ongoing Monitoring: The company is responsible for continuously monitoring its business relationships and the financial flows associated with them. This ongoing scrutiny ensures that any changes in client behavior, transaction patterns, or risk profiles are promptly detected, investigated, and addressed to prevent illicit activities.
Identification and Verification of Beneficial Ownership: Tide Table Logistics Ltd rigorously identifies and verifies the beneficial owners of corporate clients, ensuring transparency in ownership and control structures. This process helps prevent the concealment of illicit proceeds behind complex or opaque corporate entities.
Suspicious Activity Reporting: The Regulations require the timely and accurate reporting of suspicious transactions or activities to the United Kingdom’s Financial Intelligence Unit, which is operated by the National Crime Agency (NCA). Tide Table’s Compliance Officer is the designated point of contact responsible for preparing and submitting Suspicious Activity Reports (SARs) in accordance with legal requirements.
Training and Internal Controls: The company maintains robust internal control systems designed to prevent financial crime. These include documented AML policies, transaction monitoring procedures, client screening protocols, and effective record-keeping practices. In addition, Tide Table Logistics Ltd provides regular, mandatory AML training to all relevant employees, contractors, and agents, ensuring they are fully aware of their obligations under the Regulations and capable of recognizing and responding to potential risks.

Alignment with Global Standards and Industry Guidance

In addition to compliance with UK-specific legislation, Tide Table Logistics Ltd aligns its AML framework with internationally recognized standards, notably:

The Financial Action Task Force (FATF) Recommendations, which represent the global benchmark for anti-money laundering and counter-terrorist financing measures. By following FATF guidance, the company ensures that its AML program meets or exceeds international best practices.
The UK Joint Money Laundering Steering Group (JMLSG) guidance, which offers practical interpretation and detailed instructions on implementing the Money Laundering Regulations within UK businesses. Tide Table follows these recommendations to ensure consistency, clarity, and effectiveness in applying regulatory requirements.

By strictly adhering to the UK Money Laundering Regulations 2017 and its associated guidance, Tide Table Logistics Ltd demonstrates its commitment to legal compliance, operational integrity, and the prevention of financial crime within all its UK-based and international operations.

2. Republic of Ghana: Anti-Money Laundering Act, 2020 (Act 1044)

In addition to adhering to UK legislation, Tide Table Logistics Ltd operates within the jurisdiction of Ghana, where it holds a licensed operational base. Consequently, the company is fully bound by the provisions of the Anti-Money Laundering Act, 2020 (Act 1044) of the Republic of Ghana. This Act establishes a legal and regulatory framework aimed at detecting, preventing, and punishing money laundering, terrorist financing, and related financial crimes within Ghana’s financial and commercial sectors.

Under the oversight of Ghana’s Financial Intelligence Centre (FIC) — the national authority responsible for receiving, analyzing, and disseminating suspicious transaction information — Tide Table Logistics Ltd is committed to implementing stringent AML measures consistent with local laws and regulatory expectations.

Core Obligations Under Ghana’s AML Act

Tide Table Logistics Ltd undertakes the following key responsibilities to comply with Ghanaian AML requirements:

Implementation of Institutional AML Controls: The company maintains comprehensive anti-money laundering policies, procedures, and internal controls tailored to its Ghanaian operations. These controls ensure that all departments and personnel operating within Ghana apply consistent and effective AML safeguards throughout all stages of commodity trading, financial transactions, client onboarding, and document handling.
Due Diligence and Enhanced Scrutiny: Tide Table conducts thorough due diligence on all clients, intermediaries, and counterparties connected to its Ghana operations. This includes verifying identity, ownership, and legitimacy of entities involved. For high-risk clients — such as those based in high-risk jurisdictions, politically exposed persons (PEPs), or entities exhibiting suspicious characteristics — the company applies Enhanced Due Diligence (EDD) measures to mitigate potential exposure to illicit funds or terrorist financing.
Filing Suspicious Transaction Reports (STRs): When there is reasonable suspicion that a transaction or client activity may involve proceeds of crime or financing of terrorism within Ghana’s financial or trade systems, the Compliance Officer is responsible for promptly preparing and submitting a Suspicious Transaction Report (STR) to the Financial Intelligence Centre. The reporting process follows strict confidentiality and legal protocols to ensure timely intervention by Ghanaian authorities.
Record Maintenance and Cooperation: Tide Table Logistics Ltd diligently maintains accurate and secure records of all AML-related processes, client documentation, transaction data, and communication logs for a minimum of five (5) years, in compliance with Ghanaian regulatory mandates. The company also cooperates fully with national regulators, law enforcement agencies, and international partners engaged in anti-money laundering efforts, providing requested information and assistance in investigations or audits.
Training and Awareness: Recognizing the critical importance of staff awareness in combating financial crime, Tide Table Logistics Ltd ensures that all Ghana-based employees, contractors, and agents receive ongoing AML training. These programs focus on identifying suspicious activities, understanding regulatory requirements, and responding appropriately to potential risks in their operational roles.

Alignment with International Standards

While the Anti-Money Laundering Act, 2020 is specific to Ghana, Tide Table Logistics Ltd ensures that its AML policies and practices align with international frameworks such as those developed by the Financial Action Task Force (FATF). This alignment enhances the company’s ability to manage cross-border risks and maintain compliance with global anti-money laundering expectations.

By rigorously implementing the Anti-Money Laundering Act, 2020 and collaborating with Ghana’s Financial Intelligence Centre, Tide Table Logistics Ltd reinforces its commitment to ethical business conduct, regulatory compliance, and the prevention of financial crime within its Ghanaian and wider international operations.

3. International Frameworks and Industry Standards

In order to uphold the highest standards of integrity and compliance in its global operations, Tide Table Logistics Ltd aligns its Anti-Money Laundering (AML) policies and procedures with internationally recognized frameworks and industry best practices. This approach ensures that the company not only meets local legal requirements but also maintains credibility and interoperability across diverse jurisdictions and sectors in which it operates.

Key International Instruments and Guidelines

Financial Action Task Force (FATF) Recommendations: Tide Table Logistics Ltd incorporates the FATF’s comprehensive set of 40 recommendations, which serve as the global benchmark for AML and counter-terrorist financing (CTF) efforts. These recommendations provide a framework for countries and organizations to implement effective measures covering customer due diligence, suspicious activity reporting, risk assessments, international cooperation, and regulatory oversight. By adhering to FATF standards, the company ensures it adopts a risk-based approach that is proactive, transparent, and consistent worldwide.
United Nations Convention against Transnational Organized Crime: Commonly referred to as the Palermo Convention, this UN treaty targets organized crime networks operating across borders, including those involved in money laundering, drug trafficking, corruption, and other illicit activities. Tide Table Logistics Ltd recognizes the importance of this convention in shaping international cooperation and enforcement mechanisms, reinforcing the company’s commitment to preventing its services from facilitating transnational criminal activities.
Basel Committee on Banking Supervision Guidelines: While primarily directed at financial institutions, the Basel Committee’s guidance on AML and counter-terrorism financing provides critical insights into risk management, internal controls, and compliance governance. Tide Table Logistics Ltd adopts these principles, especially in relation to financial transactions, escrow arrangements, and client verification processes, to strengthen the resilience of its operations against financial crime.
Sanctions Compliance: OFAC and EU Restrictive Measures: Compliance with international sanctions regimes is an integral part of Tide Table’s AML framework. The company rigorously screens all clients, counterparties, and transactions against sanctions lists issued by the United States Office of Foreign Assets Control (OFAC), the European Union (EU), and other relevant authorities. This screening helps prevent unauthorized dealings with designated individuals, entities, or countries subject to trade or financial restrictions, thereby mitigating reputational and legal risks.

Industry Best Practices

Tide Table Logistics Ltd benchmarks its AML practices against those implemented by leading global commodity brokers, financial institutions, and marine service providers, ensuring that its procedures remain current, effective, and aligned with sector-specific risks. These best-practice protocols include:

Robust Know Your Customer (KYC) and Enhanced Due Diligence (EDD) frameworks tailored to the complexities of high-value commodity trades and cross-border logistics.
Use of advanced transaction monitoring systems and data analytics tools to identify unusual patterns and potential red flags.
Regular AML training programs for employees, contractors, and partners to foster a culture of compliance and vigilance.
Strong emphasis on third-party risk management, including due diligence on suppliers, joint venture partners, and service providers involved in commodity supply chains.

By integrating these international standards and industry best practices, Tide Table Logistics Ltd not only safeguards its business against financial crime but also strengthens its reputation as a responsible and trustworthy participant in the global trade ecosystem.

By aligning with these multilayered compliance frameworks, Tide Table Logistics Ltd protects its operations from legal, financial, and reputational risks. This alignment further solidifies the company’s standing as a trusted, ethical partner in global trade and maritime logistics.

To maintain this commitment, regular audits, ongoing staff training, and continuous system enhancements will be conducted to ensure that the AML Policy remains effective and adaptive to evolving regulatory requirements and emerging financial crime typologies.