Every counterparty BGC engages is screened against international sanctions lists, verified for entity legitimacy, and assessed through a proprietary fraud framework — before any documentation advances. No exceptions.
BGC applies mandatory sanctions screening as a condition of counterparty engagement. No introduction is made until all four lists return clean. Matched or restricted counterparties are immediately disqualified.
U.S. Office of Foreign Assets Control — Specially Designated Nationals and Blocked Persons. Screened against the consolidated list including all program-specific entries.
Required — No ExceptionsEuropean Union restrictive measures consolidated list. Covers individuals, entities, and vessels subject to EU financial sanctions and asset freezes.
Required — No ExceptionsUnited Nations Security Council consolidated sanctions list. Covers all active committee regimes including 1267/1989 (Al-Qaida), 1988 (Taliban), and country-specific programs.
Required — No ExceptionsHis Majesty's Treasury Office of Financial Sanctions Implementation. Applied manually against the UK consolidated list, which diverged from EU upon Brexit and is maintained independently.
Required — No ExceptionsSanctions clearance is necessary but not sufficient. BGC separately verifies entity legitimacy, contact authenticity, and mandate plausibility before any counterparty advances past the submission stage.
Certificate of incorporation or equivalent trade license verified against the stated jurisdiction. Registered trading address and company number confirmed.
Domain age, registrar, and ownership history reviewed. Company email preferred — free-email submissions (Gmail, Yahoo, etc.) are accepted but subject to enhanced verification.
Stated volume, delivery basis, product specifications, and procedure sequence reviewed for commercial plausibility. Mandates inconsistent with known market practice are flagged.
G7 price cap compliance assessed. Transactions involving Russia, Iran, Venezuela, DPRK, Syria, or Belarus are declined regardless of stated routing or documentation structure.
BGC does not engage in transactions involving the following origins, destinations, or beneficial ownership jurisdictions — regardless of stated routing, third-country intermediaries, or documentation structure.
Novatek, Rosneft, and other OFAC/EU/UK-designated entities are likewise excluded regardless of any claimed exemption, third-party structure, or price-cap documentation.
BGC maintains a proprietary assessment framework for identifying fraudulent mandates, fabricated documentation, and bad-faith actors in the petroleum brokerage space. The specific criteria applied are not disclosed publicly — publishing a checklist functions as a how-to guide for circumvention.
Counterparties that fail BGC's fraud assessment are disqualified immediately and permanently. BGC maintains an internal do-not-engage registry updated continuously from industry intelligence, community reporting, and direct verification failures.
If you believe you have encountered a fraudulent party misrepresenting an association with BGC — or soliciting advance fees in BGC's name — contact tanya@baumglobalcommodities.com directly. BGC charges no upfront fees of any kind.
BGC's Non-Circumvention, Non-Disclosure and Irrevocable Master Fee Protection Agreement is executed bilaterally at the point of introduction. Commission protection is irrevocable from the moment of NCNDA execution.
Both principals agree not to bypass BGC in any transaction, introduction, or relationship arising from information BGC discloses. Binding for five years from execution.
All counterparty identities, mandate terms, and pricing disclosed by BGC are confidential. Neither party may share disclosed information without BGC's written consent.
BGC's commission is irrevocably protected for the life of the transaction and any renewals or extensions. Payment flows through the agreed banking instruction regardless of how the deal closes.
BGC operates exclusively with first-tier mandate holders. Sub-mandates, unverifiable chains, and parties unable to demonstrate direct principal authority are not engaged.
BGC's due diligence process is designed to meet the standard expected by institutional buyers, major refineries, and regulated financial counterparties.
| Screening databases | OFAC · EU · UN · OFSI |
| Agreement type | NCNDA / IMFPA |
| Signature method | DocuSign e-Sign |
| Restricted territories | Fully excluded |
| Commission disclosure | Written, upfront |
| Upfront fees | None — ever |