DUE DILIGENCE QUESTIONNAIRE
Basrah Medium Crude Oil (BMCO) Sellers
Prepared to the marketing rules of the State Oil Marketing Organization (SOMO), Ministry of Oil, Republic of Iraq. Official site: www.somooil.gov.iq • [email protected]
SOMO sells export crude under term (and occasional spot/tender) contracts to qualified companies. It does not deal with requests submitted through brokers, agents, international organisations or diplomatic missions. A scanned “SOMO allocation letter” is not proof of cargo.
Best practice sequence: Standing KYC → this questionnaire → independent confirmation with SOMO (originated by Ametheus) → cargo-status documents → LC to the Central Bank of Iraq / named beneficiary → LOI / SPA.
Header
| Reference / Enquiry ID | |
| Date | |
| Completed by | Name / Company / Role |
| Contact | Email / Phone / WhatsApp |
Section A — Seller Identification
| No. | Item | Answer / Attach |
| A1 | Full legal name of the seller | |
| A2 | Role versus SOMO | ☐ SOMO term-contract holder (refiner / integrated) ☐ SOMO term trader on approved list ☐ Spot / tender awardee ☐ Trader with written mandate from a listed buyer ☐ Broker / introducer only (no title) ☐ Other |
| A3 | Registration no. / Jurisdiction | |
| A4 | Does the seller own or hold an interest in a refinery? (SOMO priority criterion) | ☐ Yes – name / location / capacity ☐ No |
| A5 | KYC already with Ametheus? | ☐ Yes – ref / date: ☐ No – full KYC attached |
| A6 | Ultimate Beneficial Owner(s) | |
| A7 | Sanctions / PEP (incl. Iraq / OFAC / EU / UN) | ☐ Confirmed clean ☐ Screening attached |
| A8 | If not the SOMO contract party: name of listed buyer + written mandate |
Section B — Title to Lift (SOMO contract / allocation)
Proves who SOMO has contracted to lift Basrah Medium. Does not prove barrels are on a ship. SOMO contract numbers typically look like MBM/… . Verification is only through official SOMO channels originated by Ametheus — not seller-supplied officers.
| No. | Item | Answer / Attach |
| B1 | Nature of title | ☐ Annual / semi-annual SOMO term contract ☐ Monthly nomination under an existing term ☐ SOMO spot / tender award ☐ Secondary sale under written mandate from the listed buyer |
| B2 | SOMO contract number | e.g. MBM / year / serial. Attach first page + signature page (confidential terms may be redacted). |
| B3 | Contract party name on the SOMO instrument | Must match A1 or the mandated listed buyer |
| B4 | Allocated / nominated BMCO volume and period | bbls / month or cargo; contract year / quarter / month |
| B5 | Grade on the contract | ☐ Basrah Medium (BMCO) ☐ Mixed / other (specify) |
| B6 | Destination restriction in the SOMO contract | ☐ Open ☐ Asia ☐ Europe ☐ Americas ☐ Other – attach clause |
| B7 | Loading terminals permitted | ☐ Basrah Oil Terminal (BOT) ☐ Khor Al-Amaya (KOT) ☐ Iraqi SPMs ☐ STS outside Hormuz (only if SOMO tender/contract says so) |
| B8 | Documents attached for title | ☐ SOMO contract extract ☐ Current monthly nomination / lifting programme letter from SOMO ☐ Mandate if seller is not the contract party ☐ Consent for Ametheus to verify with SOMO |
| B9 | Is this volume still unlifted / unencumbered? | ☐ Yes ☐ No – explain |
How Ametheus verifies: official email to [email protected] and/or the relevant SOMO Basrah desk (e.g. [email protected]), using contacts taken from somooil.gov.iq — not from the seller. Ask SOMO only: contract number, contract party, grade, remaining volume, loading month.
Not accepted as title: ministerial / “special committee” letters; broker allocations; ICPO-for-allocation schemes; hotel or embassy introductions; any paper that SOMO will not confirm in writing.
Section C — Proof of Cargo (choose one path)
A SOMO contract is not a cargo. Path 1 is the standard FOB Basrah lifting. Path 2 (already loaded / TTO) is exceptional and needs a complete SOMO-standard shipping set plus AIS that is not spoofed. SOMO itself tracks tankers and flags dark / spoofed AIS.
Path 1 — Programmed / to-be-lifted cargo (standard FOB BOT / KOT / SPM)
| No. | Item | Answer / Attach |
| C1.1 | SOMO lifting programme / cargo / stem ref. for this month | |
| C1.2 | Laycan and nominated quantity | Dates + bbls (typical VLCC stem ~1,000,000 bbls ± operational tolerance) |
| C1.3 | Nominated terminal | ☐ BOT ☐ KOT ☐ named SPM |
| C1.4 | Vessel nomination status | ☐ Not yet nominated ☐ Nominated – name / IMO + Q88. SOMO must accept the vessel. |
| C1.5 | SOMO / terminal vessel acceptance | ☐ Attached ☐ Pending |
| C1.6 | Letter of Credit | Irrevocable LC in favour of the Central Bank of Iraq (or SOMO-nominated beneficiary), issued ≥ 7 days before loading, covering estimated cargo value. Bank name: |
| C1.7 | Intended destination (must match B6) |
Path 2 — Already loaded cargo (TTO / afloat) — extra scrutiny
| No. | Item | Answer / Attach |
| C2.1 | Vessel name, IMO, flag, class | |
| C2.2 | Q88 + CPA / employment | ☐ Attached |
| C2.3 | B/L — date, number, shipper (expect SOMO), consignee / to-order, quantity, load port, destination | |
| C2.4 | SOMO standard load-port set | ☐ Certificate of Origin ☐ Quality & Quantity ☐ Shore quantity ☐ Ullage ☐ Time log ☐ Manifest ☐ Sample receipt |
| C2.5 | Independent inspector at load port | ☐ SGS / Intertek / other named by SOMO |
| C2.6 | AIS position, last port, next port — confirm not spoofed / dark | |
| C2.7 | Independent contact with owner / operator / master? | ☐ Yes – contacts: ☐ No |
Not accepted as Proof of Cargo for BMCO:
– Statement of Availability / tank farm TSA (Basrah Medium is not stored in a commercial tank farm for random sale)
– Generic refinery supply contract with no SOMO contract number
– MT199 / MT799 / bank “POP SWIFT”
– Dip-test or SGS booked only after an upfront fee
– Scanned SOMO letterhead that SOMO will not confirm
– KRG / Ceyhan barrels presented as SOMO Basrah Medium unless SOMO is the shipper on the B/L
Section D — Pricing and payment (SOMO practice)
| No. | Item | Answer / Attach |
| D1 | Price basis offered | ☐ SOMO OSP for loading month ± official differential ☐ Tender / spot vs Dated Brent / ASCI / Oman-Dubai ☐ Other – explain |
| D2 | Destination basket used for OSP | ☐ Asia (Oman/Dubai) ☐ Europe (Dated Brent) ☐ Americas (ASCI) |
| D3 | Payment tenor | SOMO standard is typically 30 days after B/L date against compliant documents |
| D4 | LC beneficiary | ☐ Central Bank of Iraq ☐ SOMO ☐ Other – explain (secondary only) |
| D5 | Any request for deposit, “allocation fee”, or MT103 before LC? | ☐ No ☐ Yes – automatic decline if Yes |
Section E — Past Performance
| No. | Item | Answer / Attach |
| E1 | Iraqi / Basrah cargoes completed in last 24 months | |
| E2 | 2–3 previous cargoes | Vessel – IMO – grade – quantity – BOT/KOT – B/L month – destination |
| E3 | May Ametheus verify those liftings (AIS + documents)? | ☐ Yes ☐ No |
Section F — Red Flags
| No. | Item | Answer / Attach |
| F1 | Upfront / allocation / dip-test / anti-fraud fee? | ☐ No ☐ Yes – explain |
| F2 | Seller is a broker chain with no written mandate from a SOMO-listed buyer? | ☐ No ☐ Yes |
| F3 | Claim of ministerial / special / embassy allocation outside SOMO list? | ☐ No ☐ Yes |
| F4 | Pre-loaded vessel ready for immediate TTO? | ☐ No ☐ Yes – complete Path 2 |
| F5 | Price far below current SOMO OSP / published tender without a documented Hormuz / freight reason? | ☐ No ☐ Yes – explain |
| F6 | Vessel with dark AIS / spoofed track / frequent flag hop? | ☐ No ☐ Yes |
A “Yes” on F1 or F3 is normally an automatic decline. SOMO’s published policy is that it does not deal through intermediaries.
Section G — Commercial Details
| Proposed volume | |
| Incoterms | ☐ FOB BOT ☐ FOB KOT ☐ FOB SPM ☐ STS (only if SOMO instrument allows) ☐ CIF / CFR |
| Loading window / laycan | |
| Payment instrument | ☐ LC to CBI / SOMO ☐ Other |
| Existing SPA / LOI | |
| Other remarks |
Notes — SOMO compliance
– Section B (SOMO title) and Section C (Path 1 or Path 2) are both mandatory.
– Ametheus verifies contract numbers only through somooil.gov.iq channels it originates.
– No upfront fees of any kind.
– Destination on the B/L must match the SOMO contract restriction.
– LC in favour of the Central Bank of Iraq (or the beneficiary named in the SOMO contract) is the standard security before load.
– Information is treated as confidential.
Declaration
I/We confirm that the information and attached documents are true, accurate and current, and that the seller is not presenting non-SOMO or KRG barrels as official Basrah Medium. False or misleading information ends discussions immediately.
Name: ________________________________ Designation / stamp: ________________________________
Signature / Date: ________________________________
Submission
Return as a single PDF package to [email protected]
Subject: BMCO Seller DD – [Company Name] – [Date]
