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Compliance and governance

The file a bank, an insurer or a first-time counterparty will ask for.

Onboarding an oil and gas trading house means answering a short list of questions, in writing, with evidence — about the company, and about every cargo and vessel that moves under its name. The answers are set out here so that they can be checked before a call rather than during one. Anything marked with a bracketed dot is still being verified and is deliberately not published until it is.

Legal identity

Mundoverde Trading L.L.C. is a limited liability company established on the Dubai mainland. It trades under its own name and on its own licence; there is no group structure standing behind the trading entity that a counterparty would need to look through.

Legal name
Mundoverde Trading L.L.C.
Legal form
Limited liability company (L.L.C.)
Jurisdiction
Dubai Mainland, United Arab Emirates
Tax registration (TRN)
104222590200003
Incorporated
2022
Registered office
Office 201, Saeed Bin Nasser Al Hashar Building, Salah Al Din Road, Al Muteena, PO Box 191733, Dubai, United Arab Emirates
Bankers
Detail not yet confirmed: Bankers. [•]

Licensing and permissions

A mainland licence permits the company to trade within the United Arab Emirates as well as to import and re-export, which is the reason for the structure. The licence states the activities the company may carry on; activities outside it are not undertaken.

The current licence is available on request in the onboarding pack, together with the memorandum of association and the register of shareholders.

Available on request

  • Trade licence, current
  • Memorandum and articles of association
  • Register of shareholders and ultimate beneficial ownership declaration
  • Passport and Emirates ID copies for authorised signatories
  • Tax registration certificate
  • Bank reference letter

Counterparty due diligence

Diligence runs in both directions. Mundoverde expects to be examined, and examines in turn: a counterparty that will not evidence who owns it does not become a counterparty, whatever the margin on the cargo.

The file is opened before the first transaction, not during it, and is reviewed on a stated cycle rather than when something goes wrong.

Collected before first cargo
Certificate of incorporation or trade licence, ownership structure, ultimate beneficial ownership, signatory identification, and bank details verified against the entity name
Re-verification
Detail not yet confirmed: Counterparty re-verification interval. [•]
Responsible officer
Detail not yet confirmed: Compliance officer. [•]

Sanctions and screening

Oil and gas is the trade where sanctions exposure is most likely to arise and least likely to be accidental. Counterparties, their beneficial owners, the nominated vessel, the load and discharge terminals and the stated origin of the cargo are all screened before a transaction proceeds.

A positive match stops the transaction. It is not a matter for commercial judgement, and it is not resolved by an assurance from the party that produced the match.

Lists screened
Detail not yet confirmed: Sanctions lists screened against. [•]
Screening provider
Detail not yet confirmed: Screening provider. [•]
Screened at
Onboarding, before each cargo, at vessel nomination, and on any change of party

Vessels and cargo origin

A cargo is only as clean as the ship that lifts it and the barrels that went into it. Both are checked before a nomination is accepted, and a vessel that does not clear is refused rather than accepted with conditions.

Checked at nomination

  • IMO number, registered owner, beneficial owner and operator
  • Flag, classification society and protection and indemnity cover
  • Recent movement history, including gaps in transmission
  • Any ship-to-ship transfer on the voyage, and where it took place
  • Stated origin of the cargo, evidenced by the certificate of origin
Vessel screening basis
Detail not yet confirmed: Vessel screening basis. [•]
Origin attestation
Detail not yet confirmed: Origin attestation requirement. [•]

Anti-money laundering

Commodity trade is a recognised route for moving value, and the recognised methods are unsubtle: invoices that do not match the cargo, payment from a party that is not the buyer, and a voyage routed through a port with no commercial reason to be on it.

Mundoverde therefore invoices the contracting party, accepts payment only from that party, and declines third-party settlement. Where a transaction has a feature that cannot be explained commercially, it does not proceed on the strength of an explanation offered afterwards.

Standing rules

  • Payment is accepted only from the contracting counterparty, in the contracting entity's name
  • Third-party and cash settlement are declined
  • Invoice value must correspond to the cargo described, inspected and certified
  • Routing without a commercial rationale is questioned before the vessel is fixed
  • Requests to alter documents after presentation are refused
Compliance officer
Detail not yet confirmed: Compliance officer. [•]
Compliance contact
dubai@mundo.trade

Product and quality compliance

Quality is a compliance question as well as a commercial one. A parcel that meets the contract but not the destination's fuel regulations is a problem that arrives with the vessel, so both are resolved before an order is placed.

Quality and quantity
Certificate of quality and certificate of quantity at the load port, to ASTM and ISO methods named in the contract, with sealed samples retained
Specification basis
Every limit carries the test method by which it is measured, and its tolerance
Samples
Drawn, sealed and retained at the load port for the period the contract states
Destination requirements
Applicable fuel and emissions limits checked against the discharge market before the order is placed

Insurance and risk

Who insures, on what basis and to what value follows from the Incoterm, which is why the Incoterm is written into the contract with its named port and not left to be inferred from custom. Where a route carries war or strikes exposure, that cover is arranged rather than assumed.

Delivery terms
Incoterms 2020
Cargo insurance
Detail not yet confirmed: Cargo insurance basis. [•]
Vessel cover
Protection and indemnity cover confirmed at nomination
Independent inspection
Petroleum inspection by SGS, Bureau Veritas, Intertek, AmSpec or Saybolt, appointed jointly or nominated by the buyer

Records and retention

A cargo file is kept complete: contract, due diligence, screening results, vessel record, certificates of quality and quantity, transport document, payment instrument and presentation. The value of the file is that it can be produced years later without reconstruction.

Retention period
Detail not yet confirmed: Record retention period. [•]
Held per cargo
Contract, due diligence file, screening results, vessel screening record, certificates of quality and quantity, bill of lading, payment instrument, presentation

Making a request

Onboarding, credit and correspondent banking requests are answered from a standing pack, so the turnaround depends on the request rather than on assembling the documents.