How Far Can Digitalisation End Paper-based Trade Finance? To What Extent is it Happening Now?

Presentation by Geoffrey Wynne

Partner, Sullivan & Worcester UK LLP

on 27 October 2016

At Pinners Hall, 105-108 Old Broad Street,

London, EC2N 1EX

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What areas this talk will cover ICC and others have raised focus on the subject

E-documents › Electronic warehouse receipts (eW/R) › Electronic bills of lading (eB/L) › Electronic letters of credit › Bank payment obligations (BPO)

E-signatures

Blockchain

The legal challenges each of the above creates and faces

Conclusions and the Way Forward

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E-documents: how did we get here? Some historical pointers:

1990s Citibank launches electronic scheme for customers only 1995 the Bolero Association was created central “registry” for all trade related documents of title 1996 Bolero partners with SWIFT creating a joint venture company to build, market and support the Bolero infrastructure 1999 Bolero service goes fully live 2005 essDOCS is established 2008 bitcoin is established 2016 Misys and essDOCS join forces

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Electronic trade finance Potentially wide ranging applications of technology in the trade finance world:

Electronic Letters of Credit

MT798 messaging

Electronic Bills of Lading (eB/L)

Electronic warehouse receipts (eW/R)

Bank Payment Obligations (BPO)

Distributed Ledger Technology (DLT)/blockchain

Integration of blockchain technologies

Bitcoin and other electronic currencies

Electronic platforms for receivables

the internet of things (IoT) – digital transfer of ownership – utilisation of established cloud technology to instantaneously share info around the world

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Why use e-documents in trade finance?

Many stakeholders are partnering up, investing time and money into developing usable technologies to improve trade finance.

Is technology the answer?

Current issues: increasing complexity of today’s supply chain

Processing paper documents is a time consuming/costly manual process › Tech such as MT798 can reduce complexity, allowing companies to buy from

multiple parties more easily › Reduction in transaction costs, increasing access to new customers › Potential safeguard against duplicate invoicing and increased security › Streamlining of processes, avoidance of transmission delays, facilitates faster

document checking, increased efficiencies, reduced likelihood of human error › Reduced processing time for LCs – improvements in “days sales outstanding”

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Why use e-documents in trade finance: KYC and compliance Host of trade finance regulations becoming more comprehensive,

exposing banks to reputational risk and fines

Checking non-standard paper documents can be cumbersome and carries a higher level of compliance risk

Human error could miss breaches of compliance

Technologies currently being used can lead to high “false positives”

Artificial intelligence could make filtering more effective

Cryptographic technology allows for mathematic proof a document has not been compromised – this has a potentially huge impact for KYC and other regulatory requirements

Automatic screening of content/OCR can facilitate compliance checks

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How are e-documents currently being used? Several banks and institutions have adopted disparate digital

systems to date › According to essDOCS, since 2013 banks have signed up to CargoDocs at an

average rate of one per month

Adoption of digital technologies and systems has not reached critical mass

Huge parts of the supply chain exist where no digital technology is in use

Most is bilateral – ie private arrangements between parties known to each other

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E-documents: some examples of issues

Electronic Warehouse Receipts (eW/R) › Mercuria v Citigroup [2015] EWHC 1481 (Comm) demonstrated the need for safe

storage of goods and accurate databases of receipts › Electronic warehouse receipts are currently utilised for many purposes,

including: collateral for loans from banks and other lending institutions intra-company transactions transferring ownership through the delivery process at exchanges

› Eliminates the need to store, file, safeguard and track used and unused warehouse receipts

› eW/R can be controlled and monitored centrally › Potential to cut costs and speed up process of overnight delivery or physical

transportation of paper warehouse receipts to and from lenders › May remove need to make custodial arrangements › How to develop further?

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E-documents: more issues Electronic Bills of Lading (eB/L)

› Idea has been around since eighties › eB/L allow quick transfer when cargo sold during transportation – can be sent

around world instantaneously › Reduction in administrative burden and amendments can be made at reduced cost › Electronic payment system more traceable and more secure than paper › Shortens payment cycle and improves working capital position of seller › Until 2010 the Rules of the International Group of P&I Clubs (the Group)

specifically excluded liabilities in respect of the carriage of cargo under all electronic/paperless, trading systems where the liabilities under such systems would not have arisen under a paper system

› The Group now covers some of the risks provided that the electronic system had first been approved by the Group.

Becoming more widely used – Baltic and International Maritime Council (BIMCO) included eB/L clauses in new New York Produce Exchange form – and International Group of P&I Clubs have approved three systems

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E-documents: more issues eB/Ls ability to function as document of title is not supported

universally

Present rules and laws cannot support eB/L

Who takes the risk? › ICC notes that regulators are imposing tighter restrictions and controls – will this

help to answer the above question? › Trade partners are required to sign a bilateral agreement with the platform

provider – does this make it clear who is responsible for the risks?

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E-documents: Letters of Credit Electronic Letters of Credit

› eUCP released in April 2002 and last updated in 2007 › Been in use for quite a long time

What does it allow? › Electronic use of letters of credit

Who is responsible for checking the presentation? › Who is carrying the risk if a presentation is not correct? OCR becoming more widely used, emphasis on “matching” not scrutinising

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E-documents: BPOs Bank Payment Obligations (BPO)

› URBPO launched in June 2013 › Bank assisted open account – irrevocable payment undertaking from one bank

to another following a data match › Use electronic data matching platforms – emphasis on matching of data rather

than scrutiny of data

Potential issues with BPO: › No examination of the documents › Automation and fraud risks – who carries the risks? More onerous requirements on banks to carry out due diligence on

underlying transactions and counterparties? › A promise to pay between banks only not the applicant and beneficiary Can you assign the benefit of a BPO?

› ICC suggest slow uptake because the URBPO does not apply to all parties – lack of certainty

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E-documents: where are we now? Demand for electronic trade finance

One of the barriers is that processes currently in place are difficult to break/adapt

Even if this is sorted, what about legal issues?

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E-documents: barriers to adoption Variety of participants in the process mean many parties need to invest

in and adopt processes to make e-trade finance work seamlessly › Smaller parties lack the incentive to change their processes and invest in the

technology › Market participants likely to have fears since digitalisation in trade finance not

sufficiently tested – need for international standards › EssDOCS say that they have developed systems which can be used by other parties

who have not signed up to or integrated their processes

Offering is not always better › Some still prefer “security” of an LC compared with cost savings of BPO › Higher fees associated with LC business compared to BPO – but more flexible?

Inflexibility of legacy processes › Adoption costs associated with new governance, marketing, risk management and

operational expertise › Some systems need all parties to adopt them or each to adopt a full suite of

processes, for example parties on each side of a BPO must be “BPO enabled” › eB/L not currently treated in the same legal manner as their paper equivalent

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E-documents: changing attitudes and what the future holds Are the best innovations in trade finance coming from Fintech companies?

› Desire to create “open networks”

› Increased collaboration between traditional institutions in trade finance and tech companies: R3 CEV – a blockchain tech company leading a consortium of 50+ financial

institutions working together on blockchain usage in the financial system Standard Chartered and DBS Group Holdings Ltd are developing an electronic

ledger of invoices using a parallel platform to the blockchain employed in bitcoin transactions

London Metal Exchange and Kynetix launched LMEshield, an eW/R system in April Barclays’ accelerator programme partnered with start-up Wave on eB/L solution

using blockchain Wells Fargo have pilot trade scheme with Cargill

Risk that non-traditional entrants might gain attractive elements of the value chain if banks fail to act

World Trade Board met in June 2016 and put digitalisation down as one of the three key areas of focus on the global trade agenda.

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E-documents: the risks Digitalisation in trade is happening but we have not ironed out the

risks yet

Who takes the risk if a presentation is incorrect: › the technology provider; or › the party using the technology?

Emphasis is on verification/matching not scrutiny

Coding and transaction mistakes happen

ICC paper says need to establish clear legal/regulatory framework to remove uncertainty around digitalisation

ICC want to develop initiatives to give digitalisation a legal framework acceptable to banks and counterparties

Incoming EU data protection regulation regulating data/privacy/requiring data to be ‘redactable’

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E-signature: legal framework The legal framework was recently amended and is now

underpinned by the Electronic Identification Regulation (EU/910/2014) (the Regulation) most of which came into force on 1 July 2016

The Regulation repealed the E-Signature Directive (1999/93/EC), which was the basis for the previous regulatory regime (incorporated in English law by the Electronic Communications Act 2000)

In the European Commission's view, the E-Signature Directive had failed to make online authentication an acceptable alternative to hard copy documents and written signatures in transactions requiring identification

On 25 July 2016, the Law Society published a practice note endorsing the use of electronic signatures (the LS Note)

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What is an e-signature? Article 3 of the Regulation defines an electronic signature in broad

terms as: “data in electronic form which is attached to or logically associated with other data in electronic form and which is used by the signatory to sign.”

It can take many different forms, including: › typing a name into a contract or into an email containing the contract’s terms; › clicking an “I accept” button on a website; › pasting a signature (in the form of an image) into an electronic contract; and › using a web-based electronic signature platform to generate: an electronic representation of a handwritten signature; or a digital signature using public key encryption technology and backed by a

digital certificate from the provider (or a trusted third party) verifying the identity of the signatory.

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Trust services and trust service providers

The Regulation seeks to address the fragmented nature of trust services across the EU

It therefore replaces the role of certificate service providers (CSPs) (as they were under the E-Signature Directive) with the concept of trust service providers (TSPs)

A TSP is an entity providing one or more "trust services", which are electronic services, normally for remuneration, consisting of: › the creation, verification, and validation of electronic signatures, electronic seals

or electronic time stamps, electronic registered delivery services and certificates related to those services;

› the creation, verification and validation of certificates for website authentication; and

› the preservation of electronic signatures, seals or certificates related to those services.

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Qualified trust services Regulation also introduces the concept of qualified trust services

and qualified TSPs

Qualified TSPs can provide qualified certificates and are subject to a more comprehensive and harmonised regulatory regime than that which existed for CSPs issuing qualified certificates under the E-Signature Directive

The introduction of this harmonised regime is intended to ensure that qualified TSPs across the EU meet the same high-level security standards

Member States are required to designate a supervisory body with responsibility for supervising TSPs (Article 17)

In the UK, the government has designated the Information Commissioner's Office as the supervisory body for TSPs

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Trust mark Qualified TSPs are permitted to use the new EU trust mark from

July 2016 to identify their services in a simple, recognisable and clear manner (Article 23):

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Liability Article 13 of Regulation provides that all TSPs (qualified and non-

qualified) are liable for damage caused intentionally or negligently due to a failure to comply with their obligations under the Regulation

However, only qualified TSPs will be assumed to have acted intentionally or negligently unless it can prove otherwise

The burden of proof in relation to non-qualified TSPs remains with the person claiming damage

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Legal effect of e-signatures The Regulation maintains the position established under the E-

Signature Directive: an electronic signature should not be denied legal effect and admissibility as evidence in legal proceedings just because it is electronic or fails to meet the requirements for a qualified electronic signature meaning, an advanced electronic signature that is created by a qualified electronic signature creation device, and which is based on a qualified certificate for electronic signatures.

However, only a qualified electronic signature is automatically granted the equivalent legal effect of a handwritten signature (Article 25)

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Legal effect of e-signatures Article 26 provides that advanced electronic signatures must be all

of the following: › uniquely linked to the signatory; › capable of identifying the signatory; › created using electronic signature creation data that the signatory can, with a

high level of confidence, use under his sole control; and › linked to the data signed therewith in such a way that any subsequent change in

the data is detectable.

A qualified electronic signature based on a qualified certificate issued in one Member State now benefits from mutual recognition in all other Member States

However, if Britain exits from the EU the Regulation might: › automatically cease to apply; or › continue to apply through the EU law principle of mutual recognition.

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Mercury v HMRC [2008] EWHC 2721 (Admin)

In Mercury the parties to a (lawful) tax avoidance scheme had created documents, purportedly executed as deeds, by inserting signed pages from earlier drafts in to a final version

The court held that the documents had not been properly executed as deeds

Mercury does not allow a signature page to be produced independently and then bound into a "deed", where that signature page has never been part of the whole (concluded) deed

The Mercury decision however caused widespread concern about the process of signing and completing legal agreements under English law.

Many businesses are now, as a result, still organising physical signing meetings to conclude a transaction that could otherwise have been concluded electronically

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LS Note – deeds Deeds:

› deed can be validly executed by a company: by each of two directors signing the deed (using an electronic signature or

another acceptable method) either in counterpart or by one director signing, followed by the other adding his or her signature to the same version (electronic or hard copy) of the deed; or

by a director e-signing with another individual genuinely observing such signature and that witness subsequently signing an adjacent attestation clause (it is noted that best practice would be for the witness to be physically present, rather than witnessing through video conferencing or other live medium).

› an individual can validly execute a deed by e-signing under the “genuine observation” of a witness in the same way as described above for a director

› delivery of a deed can be achieved through e-signing, however, as with wet-ink signatures, parties should explicitly address when delivery takes place if it is not intended to be at the time of signature

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LS Note – documents in writing Documents subject to a statutory requirement to be in writing

and/or signed and/or underhand (e.g. statutory requirements for bills of exchange, guarantees or promissory notes): › a contract executed using an electronic signature (and which may exist solely in

electronic form) satisfies a statutory requirement to be in writing and/or signed and/or under hand

Board minutes and written resolutions can be validly e-signed if they are subsequently: › sent or supplied in hard copy form by or on behalf of the person who signed it;

or › sent or supplied in electronic form, provided that the identity of the sender is

confirmed in a manner specified by the company or (where no such manner has been specified by the company) if the communication contains or is accompanied by a statement of the identity of the sender and the company has no reason to doubt the truth of that statement.

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LS Note – other points There is no reason why a document cannot be signed using a

combination of e-signatures and wet-ink signatures

It should be noted that some authorities or registries (e.g. the Land Registry) still require a wet-ink signature on certain documents

Where an overseas company is to sign an English law document electronically, or the document is not governed by English law, parties should seek advice from foreign counsel

The LS Note provides only non-binding guidance on execution and completion practices

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What is blockchain? Blockchain is a database operating through ‘distributed ledger

technology’ – i.e. an online ledger which allows two or more entities that do not necessarily know each other to agree that something is true without the need of a third party to certify ownership and/or clear transactions

Users agree that something is true by way of pre-agreed consensus algorithms in the applicable participating network

It records ownership by taking a number of inputs and placing them into a ‘block’. Each block is then 'chained' to the next block using a cryptographic signature

This allows ‘blockchains’ to be used as a safe ledger accessible by anyone with permission to do so

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Open or closed? Blockchain-based distributed ledgers may be customised along a

spectrum of decentralisation: › public ledgers – fully decentralised among its servers, with transactions that are

transparent but pseudonymous (i.e. users are given a cryptographic identity for which it is up to them to either declare their personal details or keep the transaction private)

› partially decentralised ledgers – the ledger, servers and users may be subject to certain constraints imposed by e.g. a consortium of entities that controls all changes to the ledger, or controls user permissions

› private ledgers – a single trusted entity controls all changes to the ledger, or controls user permissions

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Digital currencies More than 500 cryptocurrencies are in use today, but bitcoin is the

most used

The idea of bitcoin as a ‘currency’ is a misconception

It is a digital commodity which can traded on blockchain – it is “both a piece of the ledger and an asset on the ledger”

Regardless of its definition, bitcoin is a “disruptive” technology – displacing established market leaders – that can facilitate cross-border transactions: › it can be sent anywhere in the world at nearly zero cost › it is nearly impossible to counterfeit › it can be divided into smaller parts than a cent/pence

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Blockchain applications in trade finance

Some blockchain properties arguably lend themselves extremely well to trade finance programmes, such as: › immutability and timestamping › provenance of goods › streamlining settlement › peer-to-peer transfer of ownership of digital assets › smart contracts (i.e. electronic contracts than can be executed automatically

once certain conditions are satisfied) › secure distribution of ‘single source of truth’ (i.e. the practice of storing data

exactly once)

Relevant to secondary loan trading, supply chain finance, commodities trading

Put together, these properties could create the framework for an automated supply chain with a potential to improve: › supply chain logistics › management and supply chain finance

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Reducing risk (and related costs) Each transaction in the ledger is openly verified by a community of

networked users, arguably making the distributed ledger tamper-resistant (e.g. duplicate invoices and malicious parties can be detected and reported much faster)

A searchable historical record of all transactions is created, enabling, it is said, effective monitoring and auditing by participants and regulators (e.g. AML/anti-terrorism regulations and KYC requirements)

Almost any intangible document or asset can be expressed in code (‘tokenised’) which can be programmed into or referenced by a distributed ledger such that: › ownership can be proven › transfer of title would be real-time and peer-to-peer

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Real-world example: buyer-led receivables

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Supplier (Seller)

Service Provider/ Financer

Debtor (Buyer)

Supply Contract

1. Purchase Order

2. Supplies goods/services and invoice

5. Request for financer to purchase receivable

6. Payment of discounted purchase price in exchange for assignment of receivable

8. Payment of face value of receivable on maturity date

7. Notice of assignment of

receivable

Steps 1 to 8 are performed

through a single shared platform

Financer

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Real-world example: buyer-led receivables

Buyer’s inventory management system detects it is running low on steel

Step 1 – once steel inventory drops below a certain level, a purchase order is automatically sent to the Seller (via e.g. a smart contract)

Step 2 – the Seller ships the correct amount of steel and automatically issues an invoice for the goods to the Buyer

Steps 3 and 4 – the Buyer performs a three-way match and automatically approves payment with a cryptographic signature. The signature confirms to the Seller the approval and a promise to repay on the due date

Steps 5 and 6 – the Seller sells the receivable and receives early payment from the Financer. Another option would be to sell receivables automatically based on e.g. - › discount rate › seller’s current cash balance

35 Source: GTR guide to blockchain for trade finance

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LC transaction using multiple platforms

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Manual pre-screening.

Letter of credit.

Shipping arranged.

Manual checks.

Paper-based verification to be completed.

Contracts manually

completed.

Manual KYC and due diligence is

time consuming.

Limited access to data means many

SMEs cannot access finance.

Lack of transparency

over exact condition of

goods in transit.

Process of manual checks is costly and creates

a higher turn-around time.

Unavailability of authorised

signatories to sign the paper

requests.

Main points:

Source: Santander InnoVentures – Fintech 2.0 Paper

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LC transaction using a single platform

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Real time capturing of trade data.

Letter of credit.

Shipping arranged.

Real time monitoring.

Real time verification and digital

submission.

Smart contract auto

filled.

Better underwriting

and credit decisions.

Authorisers can approve requests remotely.

Better knowledge of the condition of goods.

End customers can track their goods improving

trust.

Verification of goods is more reliable and in

real time.

Elimination of documentation speeds process

and reduces costs.

Main points:

Source: Santander InnoVentures – Fintech 2.0 Paper

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Blockchain: the long view (2022) Application of the concept of ‘just-in-time, automated financing’ to

the entire supply chain and trade networks = › Increases in efficiency and utilisation of working capital in global commerce

Adoption of a large blockchain-based lender network including top financial institutions and trade finance programmes = › Drop in title ownership and transfer risks for lenders that are part of the network

Collection of granular data in a searchable and continually updated blockchain network = › Creation of a global trade finance index or rating helping inform credit decisions.

Blockchain could displace some or all of SWIFT’s current role in banking

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Blockchain: the reality (2016) We are still living in the late 1990s ‘internet’ stage of blockchain

Overall, blockchain has only been tested by market participants on a small, focused scale – nowhere near the degree of scale needed to realise the benefits of blockchain in trade finance

Over the last year R3 CEV claims 45 financial institutions have joined a consortium aiming to develop universal standards and a shared protocol for blockchain networks

Blockchain promises to reduce banks’ operational and compliance costs that come with paper-based trade financing by: › 10-15% according to the R3 CEV consortium › $15-20 billion per annum by 2022, according to Santander

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Blockchain: the reality (2016) Interest is certainly increasing:

› BoE and the EC have conducted studies on the utilisation of cryptocurrencies and blockchain technology

› Santander UK to use blockchain for B2B and consumer international payments through a new app

› Citigroup to use its own blockchain and cryptocurrency Citicoin › Emirates NBD and ICICI Bank have partnered with a subsidiary of Indian tech

giant Infosys on a pilot blockchain solution for trade finance › Dun & Bradstreet is testing a blockchain distributed ledger for offering its

proprietary corporate data to business customers › In September 2016, Barclays announced “the first blockchain LC transaction”

between Ornua and the Seychelles Trading Company part of a regular flow of LCs between the two parties, but relatively small in

amount (under $100,000) documentation handled on the “Wave” platform, with funds sent via SWIFT

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Blockchain: the risks In an imperfect world, who takes the risk if a transaction is

reflected incorrectly on the distributed ledger: › the party(ies) responsible for inputting the relevant block of information? even in the event of fraud?

› the party(ies) providing the blockchain platform and related protocols? even if caused by events outside its control?

Data is permanently/immutably embedded by default › confidentiality and/or privacy rules might not easily be complied with: can the technology secure the financial information provided? If not,

questions of waivers and consents arise new US and EU regulations (e.g. EU General Data Protection Regulation) all

require personal financial data to be redactable — something that is not possible on an immutable platform

› operational errors and illegal or nefarious activities could stand uncorrected › to remove the above risks, previous blocks of information must therefore be

capable of being edited (under extraordinary circumstances) without breaking the chain 41

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Blockchain: the risks In a fully or partially decentralised global blockchain network where parties are

unable to identify a single place on which the data is held, it may be difficult to: › identify the appropriate set of domestic rules to apply to both contract and

property rights › pinpoint which jurisdiction would apply in the event of a breach or fraud within

the network.

Smart contracts present enforceability questions if attempting to analyse them within the traditional ‘contract’ definition (i.e. offer, acceptance, consideration and intent)

The legal status of online entities used to execute smart contracts and record blockchain activities is open to interpretation – questions of ownership and responsibility also arise

Pseudonymous distributed ledger platforms raise transparency and anti-money laundering / compliance issues

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Blockchain: the risks As with SWIFT, the security of the blockchain process is not

absolute and largely depends on the users’ good practice › paper-based trade finance might be inconvenient and costly, but it is relatively

safe from cyberattacks › private or partially decentralised ledgers could be at risk of a focused cyberattack

on the central server(s) that validate transactions

Blockchain could therefore enable fraud and service disruption cyberattacks on unprecedented scales

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Conclusions and way forward How far can digitalisation end paper-based trade finance?

There is increasing development of technology in trade finance

The uptake of digital technologies in trade finance has not been as fast as some may have anticipated › legacy systems › faster adoption in certain regions (Asia)

Questions around which party carries the risk remain key › Would you accept the risk?

Need for coordinated regulations/codes of practice › ICC are currently examining the role they should play in this › new EU regulation on data protection and processing of private information

Developments in distributed ledgers and its immutability may help increase adoption of rules particularly for KYC/compliance

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Dates for your diary

10 November – 3rd Anniversary Party

24 November – next seminar

15 December – last seminar for 2016

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Geoffrey L Wynne Partner Geoffrey Wynne is head of Sullivan & Worcester’s London office and also head of its Trade & Export Finance Group. He has extensive experience in banking and finance, specifically trade and structured trade and commodity finance. He also advises on corporate and international finance, asset and project finance, syndicated lending, equipment leasing and workouts and financing restructuring.

Geoff is one of the leading trade finance lawyers and has advised extensively many of the major trade finance banks, multilateral financers and companies around the world on trade and commodity transactions in virtually every emerging market including CIS, Far East, India, Africa and Latin America. He has worked on many structured trade transactions covering such diverse commodities as oil, nickel, steel, tobacco, cocoa and coffee. He has worked on warehouse financings in many jurisdictions and advised on how to structure involving warehouse operators and collateral managers. He has also advised on ownership structures and repos for commodities and receivables financings.

Geoff sits on the editorial boards of a number of publications and is a regular contributor and speaker at conferences. He is also the editor of and contributor to The Practitioner’s Guide to Trade and Commodity Finance published by Sweet & Maxwell and A Guide to Receivables Finance, a special report from TFR published by Ark.

Sullivan & Worcester UK LLP Tower 42 25 Old Broad Street London EC2N 1HQ

T +44 (0)20 7448 1001 F +44 (0)20 7900 3472 gwynne@sandw.com

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Awards & Recognition TFR “Best Law Firm in Trade Finance”

Trade & Forfaiting Review (TFR) named Sullivan & Worcester "Best Law Firm in Trade Finance" in its 2014, 2015 and 2016 TFR Excellence Awards GTR “Best Law Firm 2015 Poll”

Sullivan & Worcester UK LLP was top ranked firm in the Global Trade Review (GTR) Best Law Firm 2015 poll The Legal 500 UK 2016

Sullivan & Worcester UK LLP was ranked in the following category in The Legal 500 UK:

› Trade Finance (Tier 1)

Chambers UK 2016

Chambers UK ranked Sullivan & Worcester UK LLP, along with Geoffrey Wynne and Simon Cook in the following area:

› Commodities: Trade Finance (UK-wide)

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