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Supplier verification for commodity trade: entity, mill and goods

Screening the trader is not the same as screening the producer of the cargo. KYC, UBO and sanctions checks are related steps, not a certificate that a counterparty is safe.

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How the pieces fit

Supplier verification is the file that asks whether this legal person, this mill or plant, and these goods can be taken into a transaction. KYC establishes who the company is. UBO identification looks through to the natural persons who own or control it. Sanctions screening checks product, producer and parties against applicable lists and rules. Document verification checks that certificates match names and lots. Commercial verification checks that capacity and grades can actually be described. None of these steps, alone or together, means a counterparty is “fully verified”, risk-free or guaranteed.

Who is on the file

Legal existence comes first: registered name and jurisdiction, matching the letterhead. Then say whether the performing producer is the same company as the trader. A permitted trader does not make a restricted mill eligible. A stockholder should be able to show that the material exists and can be inspected.

KYC and UBO in a trade file

KYC answers who the legal person is. UBO answers who ultimately owns or controls it. FATF Recommendation 24 is the international standard on beneficial-ownership transparency of legal persons. TTC is not a KYC software vendor and does not issue FATF certificates. See https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-R24-beneficial-ownership.html

Product, producer and documents

Compliance standing is checked against the goods and the producer, not only the invoice party. Documents should corroborate identity and lot; they are not a clearance certificate for a future shipment. Banking details are confirmed later in writing, not in an unsolicited first email.

When TTC declines a file

TTC’s process can stop an inquiry after screening. That is a process outcome, not a statement that every accepted file is safe. Buyers submit an RFQ. Suppliers use supplier partnership. Do not send a marketing deck in place of corporate documents and product certificates.

Primary sources

FATF Recommendation 24 guidance: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-R24-beneficial-ownership.html

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