Standard Due Diligence
Counterparty KYC & Due Diligence Questionnaire
Know Your Customer / Counterparty Onboarding — Oleochemicals, Biofuels & Biofuel Feedstocks Trading
CONFIDENTIAL — This document contains commercially sensitive information. By completing and returning this form, you consent to the collection, processing, and storage of the data provided herein solely for the purposes of counterparty due diligence, regulatory compliance (including the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, Cap. 615), and ongoing monitoring of the business relationship. Data will be retained for a minimum of 6 years in accordance with applicable Hong Kong law.
How to complete this form
This questionnaire is organised into sections covering your company profile, ownership, compliance, and sustainability practices. Please complete every section that is relevant to your entity — required fields are marked with *.
When you have finished, export your work as a data file (⤒ Export Data) for your records. Then click ⎙ Print / Save PDF to generate a signed PDF. Email the PDF together with all supporting documents to [email protected] and your designated Genco Oil contact. Do not email the data file — only the signed PDF.
A General Company Information
Primary Contact Person
B Business & Trading Profile
Provide a comprehensive description of your business activities. This information is used for risk assessment and ongoing monitoring.
C Ownership & Corporate Structure
Disclose the full ownership chain to the ultimate parent. Attach a corporate structure chart.
Ultimate Parent / Holding Company (if applicable)
Direct Shareholders / Members (≥ 10% Ownership)
List all shareholders holding 10% or more. Continue on a separate sheet if necessary.
| Full Legal Name | Individual / Entity | Country | % Ownership | % Voting | |
|---|---|---|---|---|---|
D Beneficial Ownership Declaration
A beneficial owner is any natural person who holds ≥ 25% shares or voting rights, exercises control, or is the Senior Managing Official. Attach passport or ID copies for each UBO.
Ultimate Beneficial Owner 1
Ultimate Beneficial Owner 2
Ultimate Beneficial Owner 3
Click "Add UBO" for additional beneficial owners. Each new entry is cloned from UBO 3 format.
E Directors & Senior Management
List all directors, partners, or equivalent officers. Attach passport or national ID copies.
| Full Legal Name | Position | Nationality | Date of Birth | Passport / ID No. | Date Appointed | |
|---|---|---|---|---|---|---|
F Authorised Representatives & Signatories
List all persons authorised to enter into contracts, execute trades, and bind the company.
| Full Legal Name | Position | Scope of Authority | Passport / ID No. | |
|---|---|---|---|---|
G Financial Information
Financial data is used for credit assessment and transaction monitoring baseline. Provide the most recent audited figures.
H Source of Funds & Source of Wealth
Please describe where your funding comes from for trading activities and how the company and its beneficial owners built their wealth. This helps us meet enhanced due diligence requirements.
I Banking & Payment Details
Primary Bank Account
Secondary Bank Account (optional)
J Politically Exposed Persons (PEP) Declaration
A PEP is any person who holds or has held a prominent public function (head of state, senior government/military/judicial official, senior executive of an SOE, senior political party official). This includes domestic, foreign, and international organisation PEPs, as well as close family members and associates.
| Category | Yes | No | If Yes — Name, Position, Country, Relationship |
|---|---|---|---|
| Any Beneficial Owner (UBO) | |||
| Any Director or Senior Officer | |||
| Any Authorised Signatory | |||
| Any Shareholder (≥ 10%) |
K Sanctions & Restricted Party Screening
We screen all counterparties against UN, EU, UK (OFSI), and other major sanctions lists.
Confirm whether the entity, its directors, UBOs, shareholders, or any connected party:
| Question | Yes | No |
|---|---|---|
| Is designated on or subject to any UN, EU, UK (OFSI), or other sanctions list? | ||
| Is owned (≥ 50%) or controlled by any sanctioned person or entity? | ||
| Has operations, assets, or material dealings in a comprehensively sanctioned country (DPRK, Iran, Syria, Crimea, Cuba)? | ||
| Has ever been subject to enforcement action by any sanctions authority? | ||
| Will any goods involve shipment to/from/through any sanctioned jurisdiction? | ||
| Will any vessels, carriers, or logistics providers be flagged/registered in a sanctioned jurisdiction? |
L AML / CFT Compliance
| Question | Yes | No |
|---|---|---|
| Does your company have a written AML/CFT policy? | ||
| Do you conduct KYC / CDD on your own counterparties? | ||
| Do you have a designated Compliance Officer / MLRO? | ||
| Do you screen partners, transactions, and vessels against sanctions lists? | ||
| Do you provide AML/CFT training to staff? | ||
| Has your company ever been subject to an AML/CFT investigation or enforcement action? | ||
| Has your company ever filed an STR / SAR? |
M Anti-Bribery & Anti-Corruption (ABAC)
Please confirm your entity's anti-bribery and corruption compliance status.
| Question | Yes | No |
|---|---|---|
| Does your company have a written anti-bribery / anti-corruption policy? | ||
| Do you have procedures for gifts, entertainment, and hospitality? | ||
| Do you use agents/intermediaries for government contracts or licences? | ||
| Has your company ever been convicted of or investigated for bribery/corruption? |
N Tax Compliance — CRS & FATCA
Tax residency information is required under the Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA). These are international tax transparency frameworks that require financial institutions to report account holders' tax residency information to their local tax authority. This information helps prevent tax evasion and ensures compliance with cross-border reporting obligations. Under Hong Kong law (Inland Revenue Ordinance), we are required to collect and report this information for all counterparties.
Tax Residency
A Taxpayer Identification Number (TIN) is a unique identifier issued by a tax authority. If you do not have a TIN for a particular jurisdiction, please explain why (e.g. "jurisdiction does not issue TINs to non-residents", "application pending"). Add a row for each country where the entity is tax-resident.
| Country of Tax Residence | Taxpayer Identification Number (TIN) | If No TIN — Reason | |
|---|---|---|---|
CRS Classification *
The Common Reporting Standard (CRS) requires entities to be classified by type. This determines what information is reported and to which jurisdiction. Select the option that best describes your entity.
If Passive NFE selected: The controlling persons of the entity must be identified, and their tax residency information disclosed in the Beneficial Ownership section (Section D) of this form.
FATCA Classification *
FATCA is a US law that requires foreign financial institutions and certain non-financial entities to report on US account holders and substantial owners. Select the classification that applies to your entity for FATCA purposes.
Only required if classified as an FFI. If you have a GIIN, enter it here.
For FATCA purposes — a US Person includes US citizens, green card holders, and certain US tax residents.
O ISCC & Sustainability Certification Compliance
For biofuels and feedstocks trading, sustainability certification is critical. Please provide full details of your ISCC and other certification status including scope, certification system, and validity.
ISCC Certification Status
Other Sustainability Certifications
P ESG & Supply Chain Due Diligence
| Question | Yes | No |
|---|---|---|
| Does your company have a formal ESG / sustainability policy? | ||
| Do you have a No Deforestation, No Peat, No Exploitation (NDPE) policy? | ||
| Do you have a human rights & labour standards policy (incl. no forced/child labour)? | ||
| Can you provide traceability to the mill / refinery / production source? | ||
| Has your company been subject to ESG-related grievances, complaints, or NGO campaigns? | ||
| Do you publish a sustainability report? |
Q EU Deforestation Regulation (EUDR) Compliance
If products may enter the EU market (directly or indirectly), compliance with EUDR (EU) 2023/1115 is required. Products must be deforestation-free (cut-off: 31 Dec 2020) and legally produced. Application: 30 Dec 2026 (large/medium), 30 Jun 2027 (small/micro).
| Question | Yes | No | N/A |
|---|---|---|---|
| Are products derived from EUDR-covered commodities (palm, soy, cattle, wood, rubber, cocoa, coffee)? | |||
| Can you provide geolocation data (GPS / polygons) for production plots? | |||
| Can you confirm products are deforestation-free (post 31 Dec 2020)? | |||
| Are products produced in compliance with all laws of the country of production? | |||
| Can you submit / support a Due Diligence Statement (DDS) via the EU system? | |||
| Do you retain traceability and geolocation records for ≥ 5 years? |
R Trade References
Provide at least two trade references from companies in oleochemicals / biofuels, and one bank reference.
Trade Reference 1
Trade Reference 2
Bank Reference
S Supporting Documents Checklist
Provide certified copies. Non-English documents must include a certified translation.
Mandatory Documents
Enhanced Due Diligence — Additional Documents
Some documents may only be required depending on your answers in the form. Each item below shows when it is typically requested. Genco Oil Limited may request further documents after reviewing your submission — you will be notified if anything additional is needed.
T Declarations, Undertakings & Execution
By signing below, the undersigned authorised representative confirms and declares the following on behalf of the entity. These declarations form part of the contractual basis of the business relationship with Genco Oil Limited.
Please read carefully before signing. These declarations are legally binding and will be relied upon by Genco Oil Limited in deciding whether to enter into or continue a business relationship.
Part I — Representations & Warranties
- Accuracy & Completeness: All information, documents, and supporting materials provided in this questionnaire are true, correct, complete, and not misleading in any material respect as at the date of signing. We understand that any false, misleading, or materially incomplete information may result in the immediate suspension or termination of the business relationship and may expose the entity and its representatives to legal liability.
- Authority: The undersigned is duly authorised by the entity to complete and sign this questionnaire, to make the representations and warranties contained herein, and to bind the entity to the undertakings set out below. This authorisation has been granted by appropriate corporate action (board resolution or equivalent).
- Legal Status: The entity is duly incorporated / established and validly existing under the laws of its jurisdiction of incorporation, has full legal capacity and authority to conduct its business, and is not subject to any insolvency, winding-up, receivership, or similar proceedings.
- Sanctions Compliance: Neither the entity, nor any of its directors, officers, beneficial owners, shareholders (direct or indirect), employees, or agents is: (a) designated on or subject to any sanctions list maintained by the United Nations, European Union, United Kingdom (OFSI), Hong Kong, or any other applicable jurisdiction; (b) located, organised, or resident in a comprehensively sanctioned country or territory; or (c) directly or indirectly owned or controlled (50% or more) by a sanctioned person or entity. We confirm compliance with the United Nations Sanctions Ordinance (Cap. 537) and United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575) of Hong Kong.
- Anti-Money Laundering & Counter-Terrorist Financing: The entity is not engaged in, and will not use the business relationship for, money laundering, terrorist financing, proliferation financing, tax evasion, or any other financial crime. The source of funds used in transactions with Genco Oil Limited is lawful and derived from legitimate business activities. We understand our obligations under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) of Hong Kong.
- Anti-Bribery & Anti-Corruption: Neither the entity nor any person acting on its behalf has offered, given, promised, solicited, or authorised any bribe, kickback, facilitation payment, or other improper payment or benefit to any person — including any government official, political party, or private-sector counterpart — in connection with the business relationship or any transaction contemplated herein. We confirm compliance with the Prevention of Bribery Ordinance (Cap. 201) of Hong Kong and all applicable anti-corruption laws of other relevant jurisdictions.
- Tax Compliance: The entity complies with all applicable tax laws and reporting obligations in all jurisdictions in which it operates, including (without limitation) the Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA). The tax residency and entity classification information provided in this form is accurate and complete.
- Sustainability & Certification: Where the entity has declared that it holds ISCC, RSPO, or other sustainability certifications, such certifications are valid, current, and have not been suspended or revoked. Any Proofs of Sustainability (PoS) or Sustainability Declarations provided in connection with shipments will be accurate and issued in accordance with the applicable certification scheme rules. The entity will ensure that all sustainability data, including GHG emission values and feedstock origins, are reported accurately.
Part II — Ongoing Undertakings
- Notification of Changes: We undertake to notify Genco Oil Limited promptly in writing, and in any event within 30 calendar days, of any material change to the information provided in this questionnaire, including but not limited to: (a) changes in ownership, beneficial ownership, or corporate structure; (b) changes in directors, officers, or authorised signatories; (c) changes in registered address or principal place of business; (d) changes in the nature of business or products traded; (e) any change in sanctions status or regulatory standing; (f) suspension or revocation of any sustainability certification; (g) any legal proceedings, investigations, or enforcement actions relating to AML, sanctions, bribery, tax evasion, or fraud.
- Periodic Review & Re-verification: We acknowledge that Genco Oil Limited conducts periodic reviews of its counterparty relationships in accordance with its risk-based compliance framework. We agree to cooperate fully with any such review, including by providing updated information, documents, or certifications as reasonably requested. Failure to cooperate may result in the suspension or termination of the relationship.
- Compliance with Law: We undertake to comply with all applicable laws, regulations, and industry standards in the conduct of our business and in the performance of any transactions with Genco Oil Limited, including all applicable trade controls, export regulations, environmental laws, and — where relevant — the EU Deforestation Regulation (EUDR).
- No Circumvention: We will not take any action, or assist any third party in taking any action, that is designed to circumvent or evade any sanctions, AML, anti-bribery, or other compliance requirements applicable to the business relationship.
- Cooperation with Audits: We agree to permit Genco Oil Limited (or its authorised representatives) to conduct, upon reasonable notice, compliance audits or site visits to verify information provided herein, including verification of sustainability certifications, supply chain traceability, and source of materials.
Part III — Data, Liability & Governing Law
- Data Processing Consent: We consent to the collection, processing, storage, and transfer of personal data and corporate data provided in this questionnaire for the purposes of: (a) counterparty due diligence and risk assessment; (b) regulatory compliance (including filing of regulatory reports); (c) ongoing monitoring of the business relationship; and (d) sharing with Genco Oil Limited's affiliates, professional advisors, regulators, and third-party screening service providers as required by law or business necessity. We acknowledge that this data processing is carried out in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
- Indemnification: The entity agrees to indemnify and hold harmless Genco Oil Limited, its directors, officers, employees, and agents from and against any and all losses, damages, costs, claims, liabilities, and expenses (including reasonable legal fees) arising out of or in connection with: (a) any breach of the representations, warranties, or undertakings contained in this questionnaire; (b) any inaccuracy or incompleteness in the information provided; or (c) any violation of applicable law by the entity or its connected persons.
- Governing Law & Jurisdiction: This questionnaire and the declarations and undertakings contained herein shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region. Any disputes arising out of or in connection with this questionnaire shall be subject to the exclusive jurisdiction of the courts of Hong Kong.
- Survival: The representations, warranties, undertakings, and indemnification obligations contained herein shall survive the termination or expiry of the business relationship between the parties and shall remain in full force and effect for so long as required by applicable law.
Acknowledgments
Please confirm each of the following before signing.
Execution
This questionnaire must be signed by a duly authorised representative of the entity (director or officer with binding authority). By signing, the undersigned confirms that they have read, understood, and agreed to all declarations and undertakings above.
Signature of Authorised Representative
Company Stamp / Seal (if applicable)
For compliance queries relating to this form, please contact Genco Oil Limited's Compliance Department. Completed forms and supporting documents should be returned to your designated Genco Oil Limited contact or emailed to the compliance team. All documents will be handled in strict confidence.
✦ Internal Use Only — Risk Assessment & Approval
This section is completed by Genco Oil Limited's Compliance / Risk team — NOT by the counterparty.
| Screening | Clear / None | Match / Found | Rejected |
|---|---|---|---|
| Sanctions Screening | Escalated | ||
| PEP Screening | EDD applied | — | |
| Adverse Media | See notes | — |
| Overall Risk Rating | Low | Medium | High | Prohibited |
|---|---|---|---|---|
| Risk Rating |
| Decision | Approved | Approved w/ Conditions | Pending | Rejected |
|---|---|---|---|---|
| Final Decision |