# COUNTERPARTY KYC / AML ONBOARDING CHECKLIST

> **Complete before sharing an FCO, signing an NCNDA with fee assignment, or executing any SPA. Protects Swizz Global AG from fraud, sanctions breach, and reputational harm.**

**Counterparty ID:** `[BUY-NNN / SUP-NNN]` **Legal name:** `[__]` **Role:** `[Buyer / Supplier / Intermediary]`
**Screened by:** `[__]` **Date:** `[YYYY-MM-DD]` **Decision:** ▢ Approved ▢ Rejected ▢ More info

## 1. Legal entity verification
- [ ] Certificate of incorporation / trade licence obtained
- [ ] Company registration number verified against official registry
- [ ] Registered address confirmed
- [ ] Years in operation / trading history reviewed
- [ ] Website & digital footprint checked (consistency, age, contactability)

## 2. Ownership & control
- [ ] Ultimate Beneficial Owner(s) (UBO) identified (>25%)
- [ ] Directors / authorised signatories identified
- [ ] Passport / national ID copies for signatories & UBO
- [ ] Politically Exposed Person (PEP) check

## 3. Sanctions & adverse media
- [ ] Entity + UBO + directors screened vs **EU / SECO (Switzerland)** list
- [ ] Screened vs **OFAC (US)** SDN list
- [ ] Screened vs **UN** consolidated list
- [ ] Vessel / bank / origin country screened
- [ ] Adverse media / litigation / fraud search performed

## 4. Financial capacity
- [ ] **Buyer:** Proof of Funds (RWA / BCL / MT799) received **and** verified bank-to-bank
- [ ] **Supplier:** allocation / stock / production capacity evidenced
- [ ] Bank reference obtained; issuing bank is a recognised prime bank
- [ ] Bank coordinates independently confirmed (not just as stated by counterparty)

## 5. Transaction logic (fraud screen)
- [ ] Price is within a credible band of the market (not too-good-to-be-true)
- [ ] No advance / upfront fee demanded to "release", "allocate", or "store" product
- [ ] Counterparty willing to proceed bank-to-bank and via SPA
- [ ] Chain of intermediaries is credible; direct mandate evidence seen
- [ ] Documents (licences, POF, allocation) can be independently authenticated

## 6. Record
- [ ] All documents saved to `05_Buyers/` or `06_Suppliers/` under the counterparty ID
- [ ] Entry created in Bid System CRM (dashboard + Excel), KYC status set
- [ ] Re-screen scheduled (annually or on material change)

**Red flag → escalate / decline:** any sanctions hit, unverifiable POF, upfront-fee demand, refusal of KYC, forged or unauthenticated documents, pressure to skip steps. When in doubt, do not proceed — protect the Swizz name.