Questions this guide addresses
- Do company names, registration numbers, addresses, shareholders, signing authority and banking details match across all submissions?
- Which original documents establish beneficial ownership and authority to act, and when must they be refreshed?
- How should document submission, completed onboarding, a master agreement and confirmation of an individual cargo be distinguished?
Method and verification scope
- We anonymized recurring preparation requirements in PentaBay's records of Middle Eastern LNG counterparty questionnaires, corporate, shareholder, financial and banking evidence, confidentiality agreements and master agreements.
- Counterparties, countries, contract names and dates, personal identifiers, accounts, signatures, sanctions responses, prices, volumes, credit terms and confidential original documents are withheld.
- Public FATF, OECD and OFAC source documents were used to cross-check beneficial ownership verification, risk-based compliance and record-refresh principles. This article does not claim onboarding approval, supply rights, cargo allocation or current contract validity.
01 · Anonymized field record
Show onboarding experience through the evidence prepared, not a list of logos
PentaBay holds records of preparing submission materials for Middle Eastern LNG counterparty onboarding. These brought together corporate identity, ownership, directors and signing authority, financial statements, banking records, trade references, and sanctions, anti-money-laundering and anti-bribery responses. This article explains the assessment criteria actually used without identifying the counterparty or disclosing the contract.
The scope of disclosure is also limited. Preparing questionnaires and supporting documents establishes preparation for onboarding, not supplier approval, exclusivity, volume allocation or a completed transaction. Contract records are not used to claim that an individual cargo's price, volume, schedule or payment terms were agreed.
02 · Corporate identity
Establish a reference corporate record and reconcile every document against it
The legal name, registration number, country of incorporation and address must match across registration certificates, current registry extracts, articles of association, tax records, company profiles, financial statements and bank documents. Where English spellings, branch names, former names or abbreviations differ, distinguish the reference name from aliases and attach evidence of changes. A website or business card is supporting material, not a substitute for legal identity.
A one-character difference is not automatically an error, but an original document explaining it is needed. For address changes, changes in legal representatives or shareholdings, and reissued documents, record effective dates and explain why older material remains. Place the reference corporate information sheet at the front of the submission so onboarding staff do not have to produce a different explanation each time.
03 · Ownership & authority
Trace the shareholder list through to actual control and signing authority
A shareholder list alone may be insufficient. Trace ownership and control from direct holdings to the ultimate natural person or a verifiable higher controlling entity. Ask about voting rights, director appointment rights, joint control and nominee arrangements. FATF sets the principle that beneficial ownership information should be adequate, accurate and up to date.
Separately establish whether the person signing a contract or questionnaire has the required authority. Reconcile the scope of board resolutions, powers of attorney, registered representation rights and specimen signatures. If an agent submits the material, record the principal's and agent's roles, remuneration and the expiry of authority. Do not infer authority to bind a company from a job title.
04 · Finance & banking
Ensure financial and account records refer to the same entity and reporting period
Identify whether financial statements are audited, the reporting entity, accounting period, currency and audit opinion. If only consolidated statements are provided, explain where the onboarding entity sits within the consolidation. If the latest annual accounts are not ready, distinguish their expected completion date from interim supporting material. Do not overstate corporate capacity by selecting revenue or asset figures in isolation.
Check bank names and consistency between the account holder and corporate legal name, while removing account numbers and bank identifiers from public materials. For trade references, distinguish what the actual counterparty confirms and as of which date. Logos or contact details in a profile are not independent evidence of a track record.
05 · Compliance responses
Connect sanctions, anti-money-laundering and anti-bribery responses to evidence
Compliance questions do not end with yes-or-no answers. Assess risks using the applicable jurisdictions, operating regions, customers and suppliers, payment banks, third-party agents and products. Link the relevant policies, approvals, screening records, training and audit materials to each response. High-risk locations or complex ownership require a defined scope of further verification and specialist review rather than blanket rejection.
OFAC's compliance framework identifies management commitment, risk assessment, internal controls, testing and auditing, and training as core elements. The OECD also emphasizes risk assessment and internal controls suited to the company's circumstances in international transactions. The application of a particular law must be reassessed for each transaction; a questionnaire response does not replace a legal opinion.
06 · Version & refresh
Keep submissions, supplements, approval status and refresh dates in one record
The data room should record document names, issuing bodies, reference and submission dates, language, notarization or certification status, security classification, responsible persons and current status. Distinguish drafts from signed copies, originals from translations, and submissions from supplements. Record requested changes and response dates. Naming a file 'latest' alone conceals its change history.
Beneficial ownership, directors, addresses, banking arrangements and sanctions status can change over time. Recheck them at scheduled intervals and after changes in shareholders, representatives, accounts or operating regions, resumption after a long inactive period, a new contract or a new risk signal. Segregate or dispose of personal data no longer in use in accordance with access controls and retention policies.
07 · Evidence ladder
Label submission, onboarding, contracting, individual trades and execution as separate stages
Sending an onboarding questionnaire and evidence supports a statement that materials were submitted. Completing responses to supplementary requests establishes the review's progress, but approval should not be claimed without a separate approval notice or registration number. A master agreement provides common transaction terms; an individual cargo requires its own confirmation and conditions precedent.
In external presentations, link each stage to the document that confirms it. Submission receipts, approval notices, executed master agreements, individual trade confirmations, and shipping, inspection, document presentation and payment records establish different facts. Do not infer all preceding stages retrospectively from a single document at the most advanced stage.
Eight areas of an LNG counterparty onboarding data room
Reference documents and the key information to reconcile in each area.
| Area | Reference documents | Items to reconcile | Claims or practices to avoid |
|---|---|---|---|
| Corporate identity | Registration certificate, current registry extract and articles | Legal name, number, address and country of incorporation | Claiming verification is complete using website information alone |
| Ownership and control | Shareholder register, organization chart and registry records | Direct holdings, ultimate controller and change dates | Identifying beneficial ownership from just one shareholder |
| Directors and signing authority | Registry records, board resolutions and powers of attorney | Title, scope of authority and validity period | Inferring contracting authority from a title |
| Finance | Audited statements and supplementary records | Entity, period, currency and audit opinion | Presenting group figures as the onboarding entity's performance |
| Banking | Bank confirmation and account holder evidence | Company name, bank, currency and reference date | Disclosing account details or accepting a third-party account |
| Trade references | Orders, contracts and counterparty confirmation | Role, period, product and scope of confirmation | Presenting a logo list as completed work |
| Compliance | Policies, questionnaires, screening and approval records | Jurisdiction, subject, search date and resolution evidence | Treating yes-or-no answers as resolution of risks |
| Change control | Document index, supplement log and refresh dates | Version, status, owner and next review date | Presenting an old submission as the current position |
This table is a practical guide to preparing materials. Actual submission requirements and legal obligations vary by counterparty, jurisdiction and transaction structure. Current source documents and specialist review are needed.
Practical takeaways
- Counterparty onboarding is not simply document collection. It requires checking whether different original records describe the same legal entity and authority structure.
- Track the reference date and verification source for beneficial ownership, directors, signing authority, account holder names, financial records and compliance responses.
- Submitting onboarding materials or signing a master agreement does not establish supply allocation, an individual cargo or the current validity of the agreement.
Sources and further reading
Source titles are preserved in their original language. Figures retain the reference period stated by each source.
- Financial Action Task ForceThe FATF Recommendations ↗
International standards on customer due diligence, beneficial ownership, record keeping and risk-based measures. Based on the June 2026 revision.
Published / revised 2026-06-22 · Accessed 2026-08-31 - Financial Action Task ForceGuidance on Beneficial Ownership of Legal Persons ↗
Official guidance on verifying beneficial ownership of legal persons through multiple sources and keeping information current.
Published / revised 2023-03-10 · Accessed 2026-08-31 - U.S. Department of the Treasury — OFACA Framework for OFAC Compliance Commitments ↗
Official material identifying management commitment, risk assessment, internal controls, testing and auditing, and training in a risk-based sanctions compliance framework.
Published / revised 2019-05-02 · Accessed 2026-08-31 - OECD2021 Anti-Bribery Recommendation — Good Practice Guidance on Internal Controls, Ethics, and Compliance ↗
Corporate guidance on anti-bribery risk assessment, internal controls, third-party due diligence and record management in international transactions.
Published / revised 2021-11-26 · Accessed 2026-08-31