Governance Framework

Our Governance Framework

At ACFL Capital S.A., governance and compliance form the foundation of our operating model. As a Swiss-based financial platform engaged in trade finance, project finance, and commodity-linked transactions, we operate with institutional discipline and rigorous oversight across all mandates.

Our governance framework is designed to ensure transparency, accountability, and risk control throughout the lifecycle of every transaction. Oversight mechanisms are embedded at each stage of engagement, from onboarding and underwriting through disbursement and post-funding monitoring.

Advisory & Oversight Structure

Geneva-Based Advisory Committee

ACFL Capital maintains an independent advisory and oversight committee based in Geneva, composed of experienced professionals in finance, legal, compliance, insurance, and risk management.

The committee’s responsibilities include:

Review of underwriting and due diligence findings

Validation of compliance with AML, KYC, ESG, and sanctions standards

Oversight of transaction structuring and risk mitigation

Approval or rejection of transactions prior to execution

Risk Management & Due Diligence

ACFL Capital employs a structured risk management framework supported by independent third parties. This framework integrates external underwriting, legal review, and insurance-backed risk mitigation to ensure objective assessment at every stage of a transaction. Independent specialists are engaged to evaluate financial viability, legal enforceability, and compliance with international standards. Capital deployment is governed by escrow controls and milestone-based disbursement to reduce execution and misuse risk. This multi-layered approach ensures disciplined decision-making, transparency, and protection for all stakeholders.

Independent underwriting and feasibility analysis

Transactions are assessed by independent third-party underwriters to evaluate financial viability, technical feasibility, and execution risk. This ensures objective validation before any capital commitment is made.


Legal due diligence and enforceability review

Independent legal counsel reviews all transaction documentation to confirm enforceability, regulatory compliance, and jurisdictional integrity. This protects all parties by ensuring contracts are legally sound and executable.

Insurance-backed risk mitigation (performance guarantees)

Insurance-backed performance guarantees are used to mitigate execution and counterparty risk. These instruments provide institutional assurance that contractual obligations will be met.

Escrow-controlled, milestone-based disbursement

Funds are held in secured escrow accounts and released only upon verified achievement of predefined milestones. This structure ensures disciplined capital deployment and prevents misuse of funds.


Governance Excellence in Action

Discover how our governance framework ensures transparency, accountability, and compliance across complex financial transactions.

AML & KYC

All clients and counterparties are subject to robust AML and KYC procedures. These include beneficial ownership verification, background screening, and risk-based jurisdictional assessments. Monitoring continues throughout the life of each transaction.

Transactions are screened against OFAC, EU, and UN sanctions lists. ACFL Capital does not engage in prohibited, unethical, or illicit activities. Responsible financing principles guide all mandates.

Ongoing Monitoring

Post-funding, projects are subject to continuous monitoring and reporting. Disbursements remain conditional on compliance and milestone verification. ACFL Capital retains the right to suspend or restructure facilities if required.

ESG Considerations

Environmental, social, and governance factors are incorporated into transaction assessments. ESG alignment is treated as a core risk and reputational consideration. Projects must meet minimum international standards.

Environmental, social, and governance (ESG) factors are integrated into ACFL Capital’s transaction assessment and approval process. Each mandate is reviewed to evaluate environmental impact, regulatory compliance, and sustainability risks relevant to the jurisdiction and sector. Social considerations, including labor practices, community impact, and stakeholder engagement, are assessed to mitigate reputational and execution risk. Governance standards of sponsors and counterparties are reviewed to ensure transparency, accountability, and ethical conduct. Transactions that fail to meet minimum international ESG standards or present material sustainability risks are not approved.

Governance Rooted in Transparency

Discover ACFL Capital S.A.’s stringent governance protocols promoting transparency, accountability, and compliance in every financial transaction.

ISO 27001 Certified

Our adherence to ISO 27001 ensures the highest standards of information security management across all operations.

Regulatory Compliance Excellence

Certified frameworks align with global regulations, reinforcing our commitment to lawful and ethical financial practices.

Industry Leadership Recognition

Acknowledged by leading trade finance bodies, validating our role as a trusted partner in complex commodity transactions.