DC, SBLC & guarantee review
Compliance review of documentary credits, standby credits and demand guarantees against UCP 600, ISP98 and URDG 758 — on your own book, or as the independent reviewer appointed between two banks.
30 St Mary Axe · Instrument and project compliance
An instrument is only as clean as the projects behind it.
One standby credit can sit behind fourteen projects in nine countries. We verify each one — who owns it, where the money came from, whether it clears its own banking jurisdiction, and whether anyone in the chain appears on a list.
Beneficial ownership · Source of funds · Sanctions & PEP · Local banking jurisdiction · DC / LC · SBLC · Demand guarantees · UCP 600 · ISP98 · URDG 758
Projects behind one instrument
SBLC-2291
USD 640m · 14 projects
- Stadium redevelopment — Detroit, USCleared
- Wastewater treatment — Occitanie, FRCleared
- Pipeline section 4 — Nakuru, KEEDD
- Cold storage network — Hai Phong, VNNominee
- 10 further projectsCleared
12 cleared · 1 EDD · 1 escalated
Illustrative only
London HQ/
Geneva/
Dubai/
Singapore/
Hong Kong/
New York
Project verification
One instrument. Fourteen projects. Fourteen sets of owners.
A standby credit can sit behind a stadium in Detroit, a wastewater plant in Occitanie and a pipeline section in Kenya at the same time. Clearing the instrument tells you nothing about the projects drawing on it. Each one has its own owners, its own money and its own banking jurisdiction — so each one is verified on its own terms.
Three projects under one standby
Illustrative| Project | Jurisdiction | Regime applied | Beneficial owners | Outcome |
|---|---|---|---|---|
| Stadium redevelopment | Detroit, US | OFAC screening · BSA / FinCEN expectations · US nexus through USD clearing · municipal procurement and bribery exposure | 4 of 4 traced | Cleared |
| Wastewater treatment facility | Occitanie, FR | EU AML framework · ACPR-supervised counterparties · Tracfin reporting route · RBE beneficial ownership register | 3 of 3 traced | Cleared |
| Pipeline, section 4 | Nakuru, KE | CBK licensing · POCAMLA · FRC reporting route · BRS beneficial ownership register · FATF listing status confirmed at review date | 2 of 5 traced | EDD open |
Traced to natural persons, or it isn't traced.
A corporate name in a register is not a beneficial owner. We follow the structure until we reach people, and where we can't, we say so plainly rather than closing the file. Unresolved is a finding, not a gap.
- OwnershipProject SPV, sponsors, joint venture partners and holding chain, followed through to named individuals
- ControlDirectors, authorised signatories, nominee and trustee arrangements, and control exercised outside the shareholding
- FundsSource of funds and source of wealth for each sponsor, and evidence of where the equity actually originated
- CounterpartiesEPC contractor, offtaker, local partner and any agent, together with the procurement route that appointed them
- SanctionsUN, OFAC, UK OFSI, EU consolidated and applicable local lists, screened per person and per entity, not per project
- JurisdictionLocal banking, licensing and beneficial ownership requirements in the country the project actually sits in
- IntegrityPublic procurement and bribery exposure, adverse media, litigation and enforcement history
What we do
Compliance built for the instrument, not bolted onto it.
Screening a name tells you very little about a credit. What matters sits in the ownership, the pricing, the routing, the repeat counterparties and the documents themselves — and most control frameworks were never written to look there.
Correspondent & issuing bank diligence
Wolfsberg CBDDQ assessment, RMA and RMA Plus governance, trade line risk appetite, nested and downstream relationship identification, and periodic review of issuing and confirming bank exposure.
Risk participation & forfaiting
KYC on bank-to-bank participations under BAFT and ITFA master agreements, forfaiting under URF 800, and the diligence you need on the underlying trade before you buy or sell the paper.
Trade-based laundering red flags
Price and quantity benchmarking, dual-use and controlled goods checks, vessel and port screening, AIS gap review, duplicate and circular financing detection, and rules written to your actual trade corridors.
Policy, risk assessment & MI
Trade and project-specific business-wide risk assessment, escalation and MLRO referral paths, committee reporting, and the evidence trail that shows why each credit was confirmed, declined or escalated.
File testing, training & readiness
Second-line file sampling across live and closed credits, trade-desk and operations training, mock inspection, and remediation of back-book instrument files.
The independent role
When one bank deals with another, we can sit outside both.
Appointed by one side or jointly by both, we carry out the compliance review on the transaction and the projects behind it, and issue a written opinion to the parties who appointed us. We are not a counterparty, an intermediary or a beneficiary. Nothing settles through us.
Tri-party structure. The banks transact. We review, and we say so in writing.
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STEP 01AppointmentOne bank or both appoint us under a written mandate that names the parties, the instrument and the scope. MNDA first, always.
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STEP 02InformationDocuments come from the appointing bank through its own channels. We do not receive instruments from holders or intermediaries.
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STEP 03ReviewParties and every project drawing on the instrument: ownership to natural persons, source of funds, sanctions and PEP exposure, local jurisdiction, pricing and routing.
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STEP 04Written opinionFindings, red flags, unresolved questions and a clear conclusion — issued to the appointing parties, with the working papers retained.
What the opinion gives you
- An independent, evidenced compliance view of the transaction, its parties and every project drawing on it
- Every red flag identified, with what was done about it and what remains open
- A defensible record for your own file, your MLRO and your regulator
- A named senior signatory who will take the follow-up call
- Our professional standing behind the work, supported by professional indemnity cover
What the opinion is not
- Not a credit opinion, a rating, or a view on whether the trade or any project is commercially sound
- Not a guarantee, a surety, an insurance contract or any assumption of financial risk
- Not confirmation that an instrument is valid or enforceable — only the issuing bank can speak to that
- Not a substitute for either bank's own regulatory obligations, which remain entirely its own
- Not transferable to third parties or usable to induce anyone to enter a transaction
Scope
What we don't do.
This market carries a well-documented fraud problem. We state our limits in writing at the outset of every engagement, and we say the same thing here.
- NOWe do not underwrite, guarantee, insure or indemnify any transaction, and we take no financial position in anything we review.
- NOWe do not broker, place, introduce, monetise, discount or lease financial instruments of any kind.
- NOWe do not act for parties seeking "leased", "non-operative" or "reserved" standby credits or bank guarantees.
- NOWe do not participate in medium-term note, prime bank instrument or private placement programmes, and we do not advise on them.
- NOWe do not verify, confirm or authenticate an instrument outside an authenticated bank-to-bank channel, and we cannot do so on behalf of a non-bank holder.
- NOWe do not provide proof of funds, comfort letters, capability letters or ready-willing-and-able correspondence.
- NOWe do not take instructions from intermediaries who will not identify their principal.
We are appointed to review and to advise. We are never a party to the transaction, and no funds, instruments or risk pass through this firm. Enquiries falling outside this scope are declined without charge.
How we work
Four phases. You know the cost and the deliverable before each one starts.
Phases are gated. Nothing rolls on by default, and you can stop at the end of any of them.
PHASE 01
Scope
Discovery against your trade products, corridors, correspondent network and instrument types. Output is a written scope and a fixed fee.
PHASE 02
Diagnose
Sampling of live and closed credits, control walkthroughs from application to settlement, and correspondent file review. Findings are rated and evidenced.
PHASE 03
Remediate
Sequenced plan with owners and dates. We rewrite the framework, rebuild the red flag set, or run the file remediation ourselves.
PHASE 04
Assure
Independent testing across a fresh sample, board-ready reporting and a monitoring plan so the position holds after we leave.
The firm
Built by people who have signed off the credits themselves.
IB Compliance Solutions is a specialist trade finance compliance advisory, based at 30 St Mary Axe in the City of London. We take a small number of engagements at a time, staff them with senior people, and put every finding in writing.
- Head office30 St Mary Axe, London EC3A 8BF
- CorridorsUK, EU, Middle East, Türkiye, South and Southeast Asia, Greater China, Americas
- ClientsIssuing, advising and confirming banks, trade finance funds, regulated commodity traders
- Rule setsUCP 600, ISP98, URDG 758, ISBP 821, URC 522, URF 800, Wolfsberg Trade Finance Principles
- EngagementFixed-fee phases, senior-led delivery, no pyramid staffing
- ConfidentialityMNDA before any material is exchanged
Get in touch
Tell us what's due, and when.
A scoping call is 30 minutes and costs nothing. If we're not the right firm for it, we'll say so on the call. Please read what we don't do before enquiring — we cannot help with instrument placement, monetisation or verification for non-bank holders.