Know Your Customer framework for onboarding Seagull Maritime and Vanguard entities into client vendor master data systems. Structured for Finance-led population with Compliance-led policy and sanctions overlay — so each section has a clear owner and no requests fall through the gap.
Draft v0.1 — for discussionKYC requests come in constantly — Nakilat, Boskalis, DNK, EMF, Pacific Basin, Hafnia, Navios, Vitol — and the shape is always similar. Ten common sections, three owning teams, and a mix of finance data (bank, tax, invoicing) and compliance evidence (sanctions, policies, insurance). When the ownership isn't clear, things drop. This framework mirrors the Due Diligence portal you already know, but scoped for KYC and owned primarily by Finance.
Built to evolve. Each section below is a placeholder today. Finance + Compliance populate it together, the same way Compliance built out the DD portal over the last 12 weeks.
Core corporate identity for each contracting entity. Provided once per entity, refreshed on any incorporation change or rebranding.
Group structure and ultimate beneficial ownership — one of the highest-friction KYC items. Needs an org chart, a UBO register (anyone with >25% control), and a clear statement of ownership changes in the last 36 months (Boskalis flagged this specifically).
Current directors and officers per entity, with copies of passport / ID for KYC verification and PEP (Politically Exposed Person) declarations. Authorised signatories for contracts and banking listed separately.
Entirely Finance-owned. Errors here mean we don't get paid — this is why KYC needs Finance in the lead, not Compliance. Must be kept current and validated against contract bank details (Nakilat caught a mismatch in Nov 2025).
Standard tax-transparency regime documents. FATCA for any US-connected counterparty, CRS for almost everyone else. Tax residency certificates must be in-date; they expire annually in most jurisdictions.
Compliance-led. Clients want a clear statement of our sanctions screening process and evidence we ourselves are not sanctioned. Sanctions checks for new counterparties are managed by Compliance via the CSC channel, with documented response per request.
Already built out and in the DD portal. Linked here directly so Finance doesn't have to go hunting when a client asks. All current versions.
Compliance holds the policies, Legal confirms the scope. Client KYC typically asks for certificates plus a statement of cover limits. Insurance certificates are renewed annually — expired certificates get flagged fast in vendor systems.
Industry memberships and operating credentials. Covered comprehensively in the DD portal already — KYC typically wants certificates and a summary statement.
Final layer — references from existing clients and banking partners. Commercial owns the client relationships; Finance owns the bank side. Always needs NDA-permission before naming specific clients.