Lifecycle0
Mandatory steps
Four phases — Qualify, Contract, Clear, Settle & Close. The sequence is itself a control: no step may be re-ordered to accommodate commercial pressure.
Diligence0
Gates, none skipped
Identity, Capacity, Provenance, Structure, Approval. Commercial discussion does not advance past an unpassed gate.
Governance0
Lines of defense
The desk, independent compliance & risk with unilateral veto, and external counsel with periodic independent review.
Qualification0
DDQ questions
Across 21 sections, A through U — completed and certified by the counterparty, then independently verified.
Risk register0
Risk classes
From counterparty fraud to reputational exposure — each mapped one-to-one onto the controls register of the Transaction Procedures.
Screening0
Independent forensic providers
Dual screening above internal thresholds, on the exact settlement addresses, re-run immediately before every tranche.