Standard Operating Procedure (SOP) for Buyer Onboarding Process

1. Purpose

This SOP outlines the standardized process for onboarding new buyers to ensure compliance with Know Your Customer (KYC) requirements, risk assessment, and efficient integration into trading activities. The process collects essential corporate, trade, financial, and documentary information to verify identity, assess creditworthiness, and facilitate secure transactions. This applies to all potential buyers engaging in trades involving crude oil, petroleum products, or related commodities.

2. Scope

• Applicable to: New buyers (corporate entities) seeking to register for trading.
• Responsible Department: Compliance and Onboarding Team.
• Frequency: As needed for new buyer registrations.
• Timeline: Target completion within 10-15 business days from initial submission, subject to document verification and any required clarifications.

3. Responsibilities

• Buyer: Provide accurate and complete information, submit required documents, and respond to queries promptly.
• Onboarding Team: Review submissions, verify documents, conduct due diligence, and approve/reject onboarding.
• Compliance Officer: Oversee KYC compliance, flag any red flags (e.g., sanctions, high-risk jurisdictions), and ensure adherence to regulatory standards.
• Legal Team: Review legal documents (e.g., MOA, AOA) and translations if applicable.

4. Procedure

Step 1: Initial Contact and KYC Form Issuance

• The buyer contacts the onboarding team via email ([email protected]) or designated portal to express interest.
• The onboarding team sends the KYC Form to the buyer, along with this SOP and a checklist of required documents.
• Buyer completes the KYC Form with the following details:

Corporate Information

• Company Name
• Registered Office Address
• Date and Place of Incorporation
• List of Authorized Persons for Fund/Asset Movement (including names, designations, contact details, and signatures)
• List of Directors with Passport Numbers
• List of Shareholders and Ultimate Beneficial Owners (UBOs)
• For Shareholders with >10% Ownership: Provide Passport copies and Address Proof (e.g., utility bill or bank statement)
• Group Structure Chart (visual diagram showing ownership hierarchy)
• Credit Ratings (from agencies like S&P, Moody’s, etc., if available)
• Countries of Presence (list all countries where the company operates or has subsidiaries)
• Key Contact Details: Authorized Traders (names, emails, phone numbers)

(A) Trade Data

• Business Interests: Specify focus areas such as Crude Oil, Petroleum Products, or Others (e.g., chemicals, biofuels)
• Grades of Crude Oil/Products Traded (e.g., Brent Crude, Diesel, Jet Fuel)
• Multiple Trading Locations and Details (e.g., ports, warehouses, with addresses and capacities)
• Trading Certificate (e.g., AOT Certificate or equivalent industry certifications)
• GST/VAT Number
• Chamber of Commerce/Trade Association Membership (provide membership numbers and certificates)

(B) Financial Data

• Latest Annual Report
• Audited Financial Statements for the Last 3 Years
• Summarized Financial Data:
  • Gross Income
  • Net Profit
  • Capital
  • Reserves
  • Net Worth
• Note: Financial summaries should be extracted from audited statements and presented in a tabular format for clarity (e.g., in Excel or PDF).

Step 2: Document Collection

• Buyer gathers and submits certified copies of the following required documents:
  1. Certificate of Incorporation (CIN)
  2. Memorandum of Association (MOA)
  3. Articles of Association (AOA)
  4. Annual Accounts for Last 3 Years
  5. Banking Declaration Form (detailing authorized bank accounts for transactions)
  6. Credit Rating Certificate (if applicable)
  7. Trading Certificate
  8. VAT/GST Registration Certificate
  9. Group Structure and Holdings (detailed chart or report)
  10. Any Material Information (e.g., ongoing litigations, sanctions history, or other disclosures)
• Translation Requirement: If any documents are in a non-English language, the buyer must provide certified English translations alongside the originals.
• Submission Method: Send soft copies (scanned PDFs) to [email protected]. Hard copies may be requested for high-risk cases.

Step 3: Review and Verification

• Onboarding Team:
  • Acknowledges receipt within 2 business days.
  • Conducts initial completeness check.
  • Verifies documents against third-party databases (e.g., for sanctions screening, UBO checks).
• Compliance Officer:
  • Performs enhanced due diligence if the buyer operates in high-risk countries or has complex ownership structures.
  • Cross-checks credit ratings and financial data for consistency.
• If discrepancies or additional information is needed, notify the buyer within 5 business days with a clear list of requirements.
• Use secure channels for all communications to protect sensitive data.

Step 4: Approval and Onboarding

• Upon satisfactory verification:
  • Issue an approval letter or digital certificate.
  • Set up buyer account in the trading system.
  • Provide access credentials and training materials (e.g., trading guidelines, platform tutorial).
• If rejected: Provide reasons (e.g., incomplete KYC, compliance issues) and allow resubmission if applicable.
• Record all onboarding details in the internal CRM system for audit trails.

Step 5: Post-Onboarding Monitoring

• Conduct annual reviews of KYC information.
• Monitor transactions for any unusual patterns.
• Require updates for material changes (e.g., change in directors, financial distress).

5. Risks and Mitigation

• Risk: Incomplete or falsified information.
  • Mitigation: Mandatory certification of documents and third-party verifications.
• Risk: Data privacy breaches.
  • Mitigation: Adhere to GDPR/equivalent regulations; use encrypted emails and secure storage.
• Risk: Delays in onboarding.
  • Mitigation: Set clear timelines and follow-up reminders.

6. Appendices

• KYC Form Template: Available upon request.
• Document Checklist:

• Contact: For queries, email [email protected] or call the onboarding hotline (details provided in initial correspondence).

This SOP is effective as of January 19, 2026, and subject to periodic reviews.