At Aurillo, we place the highest importance on trade compliance, recognizing that adherence to international trade laws, national regulations, and ethical business standards is fundamental to our success and integrity. As a private enterprise engaged in both domestic and international commodity trading, our operations inherently involve navigating a wide spectrum of legal frameworks, including those governing exports, imports, economic sanctions, and customs requirements. We view compliance not as a regulatory obligation alone, but as a core pillar of our corporate governance. Our Trade Compliance program is structured to reflect this philosophy by integrating legal risk management into every operational layer of the organization. This comprehensive approach not only protects Aurillo’s business interests and reputation but also reinforces stakeholder confidence, fosters resilient partnerships, and ensures constructive engagement with regulatory authorities across the regions in which we operate.

Our compliance efforts begin with a strong commitment to regulatory alignment. We strictly observe all applicable trade laws in the jurisdictions where we conduct business. This includes, but is not limited to, compliance with export control regulations, international and unilateral sanctions programs, anti-money laundering provisions, and customs laws. The global trade landscape is constantly evolving due to geopolitical shifts, changes in economic policy, and updates to international treaties and agreements. Accordingly, our legal and compliance teams are dedicated to actively monitoring these developments, interpreting the implications for our business, and ensuring timely updates to our internal protocols. By staying ahead of regulatory changes, Aurillo can maintain agility in its operations while minimizing exposure to compliance risks. This forward-thinking stance ensures that we meet not only the letter of the law but also its spirit, embedding integrity into every transaction and strategic decision.

To translate legal obligations into consistent corporate behavior, Aurillo has developed a robust suite of internal policies and procedures. These documents provide clear and detailed guidance for all employees, outlining how trade compliance is to be upheld within their specific roles and responsibilities. Whether it involves vetting suppliers, managing cross-border shipments, or reviewing contract terms, our policies ensure a standardized approach that reflects best practices and regulatory expectations. These policies are dynamic in nature—they are reviewed regularly and revised as necessary to reflect legal updates, shifts in our trading portfolio, and emerging industry standards. The process is highly collaborative, involving cross-functional input to ensure that the policies are practical, enforceable, and aligned with operational realities. In addition, procedural documentation outlines how specific compliance tasks—such as export licensing, due diligence checks, documentation control, and internal approvals—are to be executed. This framework ensures that compliance is not siloed within the legal department but embedded throughout the entire organization.

A critical enabler of this embedded compliance culture is employee training and awareness. At Aurillo, we believe that a well-informed workforce is the strongest defense against compliance breaches. To this end, we conduct regular, mandatory training sessions for employees whose roles intersect with trade-related functions. This includes staff in procurement, logistics, finance, legal, and operations. The training curriculum is comprehensive, covering not only the technical requirements of trade regulations—such as export control classifications, restricted party screening, and customs valuation—but also the broader ethical principles underlying these laws, such as anti-bribery commitments and transparency standards. We emphasize real-world scenarios to help employees recognize red flags and understand how to respond appropriately. By promoting continuous learning and providing access to up-to-date resources, we aim to keep compliance knowledge fresh and relevant across all levels of the organization. Furthermore, our training program reinforces the message that compliance is a shared responsibility and an integral part of everyday decision-making.

Complementing our internal controls, Aurillo maintains a rigorous due diligence process for all external engagements. Before entering into any business relationship—be it with a supplier, customer, agent, or other third party—we conduct detailed screenings against relevant trade control lists, including denied party lists, sanction programs, and export control lists. Our risk-based approach to due diligence ensures that the depth and scope of the investigation are proportionate to the potential exposure associated with the transaction. We evaluate not only legal compliance but also reputational considerations, financial health, and alignment with our ethical standards. This careful vetting process mitigates the risk of inadvertent involvement with restricted entities and helps ensure that our partners operate with integrity and transparency.

Recordkeeping is another cornerstone of our Trade Compliance program. We maintain detailed records of all trade-related transactions, including contracts, commercial invoices, export licenses, customs declarations, correspondence, and internal approvals. These records are stored securely and organized systematically to ensure easy retrieval for audits, investigations, or regulatory inspections. Accurate and complete documentation not only serves as a compliance safeguard but also enables transparency and accountability throughout the supply chain. It allows us to demonstrate good faith efforts in the event of a dispute or enforcement inquiry and provides management with the data necessary for informed decision-making and continuous improvement.

To ensure that our policies and procedures are being implemented effectively, we conduct regular internal audits and compliance reviews. These audits are carried out by a dedicated team with expertise in trade law, operational risk, and process analysis. The objective is to verify compliance, identify potential vulnerabilities, and recommend corrective actions where necessary. Audit findings are reported to senior management and, depending on their severity, may trigger immediate process improvements or further investigative steps. In addition to periodic audits, we utilize monitoring technologies that track real-time trade activity and flag anomalies for review. These systems provide an additional layer of protection by ensuring that suspicious transactions are detected and addressed proactively.

Aurillo also fosters a culture of openness and responsibility through its internal reporting and investigation mechanisms. We encourage employees at all levels to voice concerns or suspicions related to potential trade compliance violations. To facilitate this, we have established secure and anonymous reporting channels that protect whistleblowers from retaliation. When a concern is raised, it is promptly escalated to our compliance and legal teams, who initiate a structured investigation. These investigations are conducted impartially and thoroughly, and any substantiated violations are met with appropriate remedial action—ranging from employee discipline to notification of regulatory authorities and implementation of corrective controls.

Technology plays a vital role in enhancing the efficiency and reliability of our trade compliance processes. Aurillo utilizes a suite of specialized compliance tools, including automated screening engines, workflow automation platforms, and real-time data validation systems. These tools streamline routine compliance checks, reduce manual errors, and enable faster decision-making. For instance, screening tools allow us to cross-reference customers and vendors against updated watch lists in real time, significantly lowering the risk of inadvertent dealings with sanctioned parties. Additionally, our technology systems are integrated with operational platforms, ensuring that compliance is embedded into procurement, logistics, and sales workflows rather than treated as a separate or reactive process.

Our commitment to compliance also extends to the accurate classification and valuation of goods for customs purposes. We follow strict protocols for assigning Harmonized System (HS) codes and determining product origin and value. This ensures that our customs declarations are accurate and compliant with applicable tariff and duty regulations. Any errors in classification or valuation could result in delays, fines, or reputational harm, which we are committed to avoiding through diligence and transparency. Our compliance team works in close coordination with customs authorities and logistics providers to remain up to date with regulatory changes and procedural requirements in each country of operation.

Finally, Aurillo has established clear and effective internal escalation protocols to respond to suspected violations or inquiries from regulatory bodies. Employees are trained to understand the appropriate channels for reporting issues and the importance of prompt escalation. Our escalation matrix outlines roles, responsibilities, and communication flows, ensuring that potential issues are elevated to senior leadership in a timely and coordinated manner. These protocols reinforce our overarching commitment to compliance and ensure that risks are managed swiftly, responsibly, and transparently.

Through this integrated and proactive Trade Compliance program, Aurillo affirms its dedication to operating responsibly, lawfully, and ethically in all markets and jurisdictions in which we do business. Our unwavering focus on compliance ensures not only our continued growth but also the sustained trust of our partners, regulators, and the communities we serve.