Compliance Framework
BGC's compliance framework is not a marketing position. It is a set of policies and procedures applied universally — to every counterparty, every engagement, without exception. The framework below governs how BGC screens, documents, and manages every ClearBridge interaction.
Applied to Every Engagement
Voluntary adoption aligned with FATF standards. Effective May 2026. Governs counterparty identification, beneficial ownership determination, and transaction monitoring obligations. Available upon request to cleared counterparties.
BGC's proprietary digital intake and verification framework. Every counterparty completes a Confidential Submission Agreement generating a unique BGC-CSA reference number. Every subsequent document is logged against that reference. Every step is timestamped. BGC holds that record in custody for every engagement.
Every counterparty is screened against the OFAC SDN List, EU Consolidated Sanctions List, UN Security Council Consolidated List, UK OFSI Designated Persons List, FuelScamAlert petroleum fraud registry, and BGC's internal Prohibited Counterparty Register before any engagement proceeds. Beneficial ownership flags and country restrictions are applied. No exceptions, no waivers, no conditional advancement past a hard-stop match.
4-stage due diligence process documented per counterparty: (1) legal entity verification, (2) beneficial ownership disclosure, (3) trade capacity and position verification, (4) fraud pattern and registry screening. A Counterparty Verification Report is generated for every engagement and held by BGC in custody.
BGC's internal disqualification list. Maintained continuously and updated on every disqualification event. Applied to all new submissions — a disqualified entity does not re-enter under a new name, a new contact, or a new principal claim. Register entries are permanent.
BGC's bilateral NCNDA/IMFPA is the sole governing instrument for all BGC-facilitated transactions. Counterparty NCNDAs are not accepted and do not govern the BGC-facilitated leg. Each NCNDA is strictly bilateral — between BGC and one counterparty only. No third parties are named, no group commission tables, no placeholders for absent parties. BGC's document governs from execution through close.
Legal Disclosures
Baum Global Commodities, LLC does not act as a Money Services Business under 31 CFR § 1010.100(ff) and is not registered as a Commodity Trading Advisor or Introducing Broker under the Commodity Exchange Act. BGC does not hold, transfer, or take title to funds or product at any point in a transaction. BGC acts solely as an intermediary broker — facilitating introductions between verified principals and earning a commission upon transaction close.
All engagements facilitated by BGC are governed by the laws of the State of California, without regard to conflict-of-law principles. Jurisdiction for any dispute arising from a BGC-facilitated engagement is San Diego County, California.
BGC's facilitation fee is product-specific, established in the bilateral NCNDA/IMFPA before any introduction is made, and earned on a success-only basis. No upfront fees are charged to any party at any stage of the ClearBridge process.
Document Suite
The following documents are issued by BGC under unique reference numbers and held in custody. Documents are available to cleared counterparties upon request.
| Document | Purpose |
|---|---|
| ClearBridge CSA | Confidential Submission Agreement — intake record issued per counterparty with unique BGC-CSA reference number |
| Compliance Clearance Certificate (CCC) | Confirms counterparty has cleared all sanctions and fraud screens — valid 90 days from issue date |
| Conditional Clearance Notice (CCN) | Flags present but no disqualifying findings — cure period applies before CCC can be issued |
| Preliminary Match Notice (PMN) | Issued at BGC's discretion when a potential counterparty match has been identified; no identity disclosed |
| Document Submission Request (DSR) | Position verification request issued to both sides independently — triggers Step 4 document review |
| Match Confirmed Notice (MCN) | Positions verified — Full, Partial, or Pending variant issued; identity not yet disclosed |
| Introduction Notice (IN) | Formal identity disclosure — issued simultaneously to both parties; IMFPA activates at this moment |
| Decline Notice | Submission has not cleared BGC review — basis not disclosed; re-submission permitted under new CSA |
| BGC NCNDA/IMFPA | Bilateral working agreement and commission protection instrument — governs from execution through close |
| BGC SCO / FCO / LOI / SPA | Deal flow document suite issued following Introduction Notice |
| Counterparty Verification Report | 4-stage due diligence record maintained per counterparty engagement |
| BGC AML/KYC Policy v1.4 | Compliance policy — available upon request to cleared counterparties |
Engage BGC
All engagements begin with the Confidential Submission Agreement through BGC's ClearBridge portal. Sanctions screening and position verification are completed before any introduction is made.