AML / KYC Policy

We are committed to preventing the use of our network for money laundering, terrorist financing, sanctions evasion, or trade in conflict minerals. Unverified counterparties do not advance through the Zorem process — regardless of commercial opportunity.

Our procedures align with FATF Recommendations 10–21, the OECD Due Diligence Guidance, and conflict-mineral due diligence consistent with Dodd-Frank Section 1502.

Before any commercial engagement, every principal is subject to structured identification: corporate registration and good-standing verification, beneficial ownership mapping to natural persons, identification of directors and authorized signatories, and confirmation of contact and banking channels.

Politically exposed persons and entities in elevated-risk jurisdictions are subject to enhanced due diligence and principal-level approval.

All principals, beneficial owners, vessels, and banking parties are screened against OFAC, EU, UN, and UK HMT sanctions lists at onboarding and on an ongoing basis throughout the relationship. A screening hit suspends engagement pending resolution; a confirmed match terminates it.

Every commodity source is verified through documented chain of custody — from mine gate, through export documentation, logistics, and refinery, to final delivery. We do not engage with paper supply or unverified claims of origin.

Supply from East and Central African corridors, including Rwanda and DRC pathways, and West African corridors is subject to corridor-specific review under the OECD Guidance's five-step framework.

Transactions proceed only after proof of product or proof of funds is established through verifiable banking channels. Instruments — including SBLC and DLC — are confirmed with issuing institutions before activation.

Counterparty files are reviewed on a risk-based cycle and upon any material change. Transaction records, verification files, and screening results are retained for a minimum of five years and made available to competent authorities where lawfully required.

Suspicious activity is escalated internally and reported to the appropriate authorities as required by applicable law.

Specialists in compliance, logistics, and trade finance are engaged as required; final accountability for every mandate remains with the principal relationship under the Founder & Principal of Zorem Commodities LLC.

Questions regarding this policy: b@zoremcommodities.com.