Compliance & Integrity

Last updated: October 2026

GW Trading LLC is committed to conducting business lawfully, ethically and transparently. The principles below apply to our directors, officers, employees and to the agents and service providers acting on our behalf.

Sanctions and trade controls

All activities are conducted in accordance with applicable economic sanctions and export control laws, including those administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce, the European Union, the United Kingdom and the United Nations. Counterparties, vessels, ports and transactions are screened against applicable restricted-party lists before engagement and on an ongoing basis. Where any activity requires governmental authorization, it is only carried out under, and within the scope of, a valid license.

Maritime compliance

Consistent with international maritime sanctions guidance, we do not knowingly engage with vessels or counterparties involved in deceptive shipping practices, such as disabling or manipulating AIS transponders, unreported ship-to-ship transfers, falsified cargo or origin documentation, or flag hopping. Vessel nomination and vetting take into account ownership, flag, classification, P&I insurance and recent trading history.

Anti-money laundering and Know Your Counterparty

We perform risk-based due diligence on counterparties before entering into any business relationship, including identification of ultimate beneficial owners, verification of corporate documentation and source of funds where appropriate. We decline business when due diligence cannot be satisfactorily completed.

Anti-bribery and anti-corruption

We prohibit bribery and corruption in all forms, whether involving public officials or private parties, in line with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and other applicable laws. Facilitation payments are not permitted, and gifts, hospitality and third-party commissions must be reasonable, transparent and properly recorded.

Health, safety and environment

We expect vessels and facilities involved in our operations to comply with applicable safety and environmental rules, including MARPOL and recognized industry standards for the quality and handling of petroleum products and marine fuels.

Fraud prevention

Our name is sometimes misused in fraudulent offers. Please see our Fraud Warning page to learn how to verify documents attributed to GW Trading.

Reporting concerns

Anyone may report suspected violations of law or of these principles, confidentially and without fear of retaliation, to [email protected]. Due diligence documentation for counterparties is available upon request in the context of a prospective business relationship.