KYC & Due Diligence in Commodity Trading: Complete Guide
Know Your Customer (KYC) and due diligence are the foundation of safe, compliant international commodity trading. This guide covers all required documentation and verification processes.
What is KYC?
KYC (Know Your Customer) is the process of verifying the identity and legitimacy of business partners before engaging in financial transactions. In commodity trading worth millions of dollars, thorough KYC protects against:
Fraud and scams
Money laundering
Terrorist financing
Sanctions violations
Non-payment risks
Reputational damage
Required KYC Documents
1. Company Registration Documents
Certificate of Incorporation:
Official company registration certificate
Must show company legal name, registration number, date of incorporation
Issued by government registry (Companies House, SEC, etc.)
Must be current (not older than 12 months for ongoing relationships)
Certified true copy acceptable
Business License:
Trading license or business permit
Specific import/export licenses if required by jurisdiction
Tax registration certificate
Chamber of Commerce registration
Articles of Association/Bylaws:
Company structure and governance
Authorized signatories
Scope of business activities
2. Proof of Identity (Directors/Beneficial Owners)
Passport Copies:
All directors and beneficial owners (25%+ ownership)
Notarized or certified copies
Must be valid (not expired)
Photo page and signature page
Some jurisdictions require national ID in addition to passport
Proof of Address:
Utility bill (electricity, water, gas) - not older than 3 months
Bank statement - not older than 3 months
Government-issued document with address
Must match address declared in company documents
Curriculum Vitae (CV):
Professional background of key persons
Relevant trading experience
References from previous business partners
3. Financial Documents
Bank Comfort Letter (BCL):
Letter from buyer's bank confirming account existence and good standing
Confirms client has been banking with them for specified period
May indicate "sufficient funds" for contemplated transaction
Does not guarantee funds or commit bank to payment
Valid for 30-90 days typically
Bank Verification Letter:
Confirms account details (account number, SWIFT code, bank address)
Verifies authorized signatories on account
May include average account balance (without specific amounts)
Financial Statements:
Audited financial statements (last 2 years)
Balance sheet, income statement, cash flow statement
Signed by certified accountant
Shows company's financial health and capacity
Proof of Funds (POF):
Bank statement showing available funds
Required for high-value transactions
May require bank officer signature and stamp
Screenshots not acceptable - must be official bank document
Ready, Willing, and Able (RWA) Letter:
Bank letter confirming client has funds and willingness to transact
More detailed than BCL
Often includes transaction-specific details
Typically valid 30-60 days
4. Tax and Compliance Documents
Tax Identification Number (TIN):
VAT number (if applicable)
Corporate tax registration
Required for international transactions and customs
Tax Clearance Certificate:
Proof of tax compliance
Shows no outstanding tax liabilities
Required in some jurisdictions
Anti-Money Laundering (AML) Declaration:
Signed statement of compliance with AML regulations
Source of funds declaration
Beneficial ownership disclosure
Sanctions Screening:
Confirmation not on OFAC, EU, UN sanctions lists
PEP (Politically Exposed Person) declaration
Some intermediaries perform automated screening
5. Trade-Specific Documents
Import/Export License:
Required for certain commodities (fertilizers in some countries)
Specific permits for chemical products
Phytosanitary certificates (for agricultural products)
Previous Trade References:
Letters from past suppliers/buyers
Proof of previous successful commodity transactions
SGS or similar inspection reports from past deals
Company Profile:
Detailed company background
Nature of business
Years in operation
Key personnel
Contact information (phone, email, physical address)
The KYC Verification Process
Step 1: Document Collection (1-3 days)
Client submits all required documents via secure email or document portal.
Step 2: Document Authentication (2-5 days)
Verify document authenticity
Cross-check with government registries
Verify bank details via SWIFT directory
Confirm passport validity with issuing country database
Step 3: Sanctions Screening (1 day)
Screen against OFAC SDN list (US)
EU consolidated sanctions list
UN sanctions list
Interpol databases
PEP databases
Step 4: Company Verification (2-4 days)
Verify company exists and is active
Check registered address
Confirm directors match official records
Review public records for adverse information
Step 5: Bank Verification (3-7 days)
Confirm BCL authenticity by contacting issuing bank
Verify SWIFT code
Check bank's reputation and regulatory standing
Confirm authorized signatories
Step 6: Risk Assessment (1-2 days)
Evaluate overall risk profile
Consider jurisdiction risk
Assess business legitimacy
Review any red flags
Step 7: Approval/Rejection (1 day)
Compliance officer makes final determination
If approved, client is onboarded
If rejected, client is notified (may not receive detailed reasons)
Total Timeline: 10-20 business days for complete KYC
Red Flags in KYC
Document Red Flags:
Poor quality scans or images (suggests forgery)
Inconsistent information across documents
Recently incorporated company for large transaction
P.O. Box as only address
Offshore jurisdiction with no business justification
Expired documents
Signatures don't match across documents
Behavioral Red Flags:
Reluctance to provide documents
Pressure to "skip" KYC
Offers of upfront payment to bypass verification
Evasive answers about business activities
Changes in company details during process
Representative can't answer basic questions about company
Financial Red Flags:
Bank in different country than company with no explanation
Newly opened bank account
Bank in high-risk jurisdiction
Financial statements don't match claimed transaction size
Refusal to provide bank verification
BCL from unknown or unranked bank
Business Red Flags:
No website or social media presence
No physical office address
Company activities don't match commodity being purchased
Claims of urgent "must do this week" transactions
Requests to modify standard procedures
Too-good-to-be-true prices or terms
Common KYC Failures and Solutions
Issue 1: Incomplete Documents
Solution: Provide checklist upfront; use document portal with clear requirements
Issue 2: Expired Bank Comfort Letter
Solution: Request new BCL before expiry; many banks issue with 60-90 day validity
Issue 3: Offshore Company Structure
Solution: Provide additional documentation explaining business structure; demonstrate legitimate business purpose
Issue 4: New Company
Solution: Director/owner's experience and references; joint venture documentation; parent company guarantee
Issue 5: Bank in Different Jurisdiction
Solution: Explanation letter; correspondent banking relationship documentation; company's international operations evidence
Enhanced Due Diligence (EDD)
For high-risk situations, Enhanced Due Diligence may include:
On-Site Visits:
Physical verification of office and operations
Meeting with management
Inspection of facilities
Third-Party Reports:
Dun & Bradstreet business reports
Credit rating agency reports
Industry reputation checks
Ongoing Monitoring:
Periodic KYC updates (annually)
Transaction monitoring
Adverse media screening
Source of Funds Investigation:
Detailed inquiry into fund origin
Business activity evidence
Historical transaction records
Data Protection and Confidentiality
GDPR Compliance (EU):
Lawful basis for processing personal data
Right to access, rectify, erase
Data retention limits
Breach notification requirements
Data Security Measures:
Encrypted document transmission
Secure storage with access controls
Regular security audits
Employee confidentiality agreements
Document Retention:
Minimum 5 years after relationship ends (regulatory requirement)
Some jurisdictions require 7-10 years
Secure disposal after retention period
Ongoing KYC (Periodic Updates)
KYC is not one-time; regular updates required:
Annual Updates:
Current bank comfort letter
Updated financial statements
Confirmation of no changes in ownership/directors
Renewed sanctions screening
Trigger Events Requiring Immediate Update:
Change in ownership (25%+ stake)
Change in directors or authorized signatories
Change in bank account
Relocation of company
Material change in business activities
Adverse news or regulatory actions
Tips for Smooth KYC Process
For Buyers/Sellers:
Prepare documents in advance - Don't wait until you find a deal
Keep documents current - Update before expiry
Organize clearly - Label all documents properly
Provide certified copies - Notarized or lawyer-certified
Be responsive - Answer queries promptly
Be transparent - Explain unusual circumstances proactively
Use professional email - Company domain, not Gmail
Have backup documents - Alternative proof if primary is questioned
For Intermediaries/Traders:
Clear requirements upfront - Provide checklist before engagement
Secure document portal - Professional impression, better security
Communicate timeline - Set expectations for verification time
Professional verification - Don't skip steps under pressure
Document decisions - Maintain audit trail
Training - Keep compliance team updated on regulations
Technology - Use automated screening tools
Escalation procedures - Clear process for high-risk cases
Conclusion
Thorough KYC and due diligence protect all parties in commodity trading:
For buyers/sellers: Ensures you're dealing with legitimate partners
For intermediaries: Prevents involvement in illicit transactions
For banks: Meets regulatory obligations
For the industry: Maintains integrity and reputation
Never skip or rush KYC. The 10-20 days required for proper verification is a small price compared to the risk of fraud in million-dollar commodity transactions.
Trading with Stratoma Interchange? Our comprehensive KYC process ensures all transactions involve verified, legitimate business partners. We only work with clients who complete full KYC.
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Keywords: KYC, know your customer, due diligence, compliance, commodity trading, bank comfort letter, trade documentation, AML, sanctions screening, verification