Compliance

How we qualify a counterparty.

The same sequence applies to every producer, buyer and intermediary we work with. It protects the people we represent and it saves everyone time: counterparties who cannot complete it are not a fit for us.

This is the common framework. Each commodity adds its own requirements on top: phytosanitary and GACC registration for food products entering China, assays and chain-of-custody for metals, forestry certification for timber, and the inspection standard agreed for each contract.

Sequence

Six steps, in order, without exception.

1 · NCNDANon-circumvention and non-disclosure agreement signed before any contact, price or document is shared.
2 · KYCCorporate registration, beneficial ownership, authorised signatory and bank reference for every party. Screening against OFAC, EU and UN sanctions lists.
3 · LOI + POFBuyers present a letter of intent with specification, volume and delivery terms, and proof of funds consistent with the transaction.
4 · FCO + POPProducers present a full corporate offer under verifiable mandate and proof of product. Mines must be operating at the time of the request.
5 · IMFPAFee protection agreement signed before the parties are introduced. Prices are benchmarked against public references (LME, LBMA, Platts).
6 · ExecutionIndependent inspection at origin, Incoterms 2020, bank-to-bank instruments (LC, SBLC). No off-channel payments, no advance fees.

What we decline

Signals that end a conversation.

Broker chainsOffers that cannot name the producer or the end buyer under NCNDA.
Off-market pricesDiscounts below public benchmarks with no verifiable reason.
Instruments before productRequests for financial instruments, deposits or fees before proof of product and inspection.
Undocumented partiesCounterparties unable or unwilling to complete KYC.