This section collects essential identification and jurisdictional information to assess baseline risk levels. Accurate completion is critical for proper risk classification.
Legal Entity Name
Trade Name/DBA
Entity Legal Structure
Individual/Sole Proprietor
Partnership
Limited Liability Company
Corporation
State-Owned Enterprise
Non-Governmental Organization
Other
Primary Operating Jurisdiction Risk Classification
Low Risk (OECD, FATF Compliant)
Medium Risk (Partial FATF Compliance)
High Risk (FATF Grey List)
Critical Risk (FATF Black List/Sanctioned)
Additional Jurisdictions of Operation (Select all that apply)
European Union
United States & Canada
Asia-Pacific (Excluding China)
China & Hong Kong
Latin America
Middle East & North Africa
Sub-Saharan Africa
Russia & CIS
Other
Years in Continuous Operation
Business Registration/License Number
Tax Identification Number
Registered Legal Address
Principal Place of Business (if different from registered address)
Corporate Website URL
Primary Contact Full Name
Primary Contact Title/Position
Primary Contact Email Address
Primary Contact Direct Phone Number
Detailed Description of Services to be Performed
Proposed Contract Start Date
Proposed Contract End Date
Anticipated Annual Contract Value (USD)
All third-party representatives must demonstrate robust anti-corruption compliance. Any affirmative response to violation questions may require additional due diligence and could affect approval.
Has the entity completed certified FCPA/anti-bribery training within the last 12 months?
Upload FCPA/Anti-Bribery Training Certificate (if available)
Does the entity maintain a written anti-bribery and corruption policy?
Upload Anti-Bribery Policy Document
Has the entity or any key personnel ever been investigated or sanctioned for bribery, corruption, or related offenses?
Has the entity ever been debarred or suspended from government contracts?
Types of Government Officials the Representative May Interact With (Select all applicable)
Customs & Border Officials
Tax & Revenue Authorities
Import/Export Licensing Bodies
Law Enforcement
Military or Defense Agencies
Judicial or Prosecutorial Officials
Legislative or Regulatory Officials
State-Owned Enterprise Executives
No anticipated interaction
Does the entity have a written policy prohibiting gifts, entertainment, or hospitality to government officials?
Does the entity prohibit facilitation payments (grease payments) entirely?
Does the entity conduct due diligence on its own third-party partners and subcontractors?
Name of Designated Compliance Officer/Legal Counsel
Will the entity provide annual compliance certifications?
Compensation must reflect fair market value for legitimate services and must not create corruption risk. All structures require justification and benchmarking.
Primary Compensation Structure
Pure Commission (%)
Commission + Base Retainer
Fixed Retainer Only
Performance-Based Bonus
Reimbursement of Actual Expenses Only
Hybrid Structure
Base Retainer Amount (USD per month)
Commission Rate (%)
Commission Calculation Basis
Percentage of Net Sales Value
Percentage of Gross Invoice Value
Fixed Fee Per Transaction
Tiered Structure Based on Volume
Profit Margin Sharing
Payment Frequency
Per Transaction
Weekly
Monthly
Quarterly
Annually
Primary Payment Method
Wire Transfer to Corporate Account
Check to Corporate Entity
Electronic Payment to Verified Account
Cash (Requires Enhanced Approval)
Third-Party Payment (Prohibited)
Cryptocurrency (Prohibited)
Justification for Selected Payment Method
Compensation Benchmarking Analysis
Service Type | Industry Low Range (USD) | Industry High Range (USD) | Proposed Rate (USD) | Variance from Midpoint (%) | Market Justification | |
|---|---|---|---|---|---|---|
Customs Brokerage | $2,000.00 | $5,000.00 | $3,500.00 | 0 | Mid-range for experienced broker in region | |
Sales Commission | $3.00 | $8.00 | $5.50 | 10 | Justified by high-value transactions | |
Does the proposed compensation exceed industry benchmarks by more than 20%?
Performance Metrics for Variable Compensation (Select all)
Net Sales Revenue
Unit Volume
New Customer Acquisition
Market Share Growth
Customer Satisfaction Score
Compliance Adherence
Other
Is there a maximum commission cap?
Payment Approval Threshold Matrix
Payment Amount Threshold (USD) | Required Approval Level | Dual Signature Required? | |
|---|---|---|---|
$0.00 | Department Manager | ||
$10,000.00 | Regional Director | ||
$50,000.00 | Compliance Officer | Yes | |
$100,000.00 | CFO | Yes | |
Total Estimated Annual Compensation
Compensation Structure Transparency Rating (1=Opaque, 5=Fully Transparent)
This section requires disclosure of all beneficial owners and screening against global watchlists. Any undisclosed ownership or red flag may result in immediate disqualification.
Ultimate Beneficial Owners (UBO) - Individuals with >10% Ownership or Control
Full Legal Name | Nationality | Country of Residence | Percentage of Ownership (%) | Politically Exposed Person (PEP)? | On Sanctions List? | Source of Wealth & Funds | |
|---|---|---|---|---|---|---|---|
John Smith | British | United Kingdom | 35 | Investment banking and real estate | |||
Li Wei | Chinese | China | 25 | Yes | Former government official - see details | ||
Upload UBO Identification Documents (Passport, Government ID)
Upload Ownership Structure Diagram
Has comprehensive PEP screening been completed for all UBOs within 30 days?
Has sanctions screening been completed against OFAC, EU, UN, and local lists?
Has adverse media screening been conducted in local and international press?
Has the entity or any UBO been subject to criminal, civil, or administrative litigation in the past 5 years?
Has the entity or any UBO filed for bankruptcy or insolvency in the past 7 years?
Potential Red Flag Indicators (Select all observed)
Unusually complex ownership structure
Use of bearer shares or nominee directors
Registered in secrecy jurisdiction
No physical office presence
Discrepancy between address and operations
Negative online reviews or fraud allegations
Unexplained wealth or cash transactions
Refusal to provide documentation
None of the above
Registered Agent/Corporate Secretary Details
Is there a physical office with staff at the registered address?
Upload Bank Reference Letter (dated within 90 days)
Professional & Trade References
Reference Organization | Contact Name | Relationship | Phone/Email | Date of Last Engagement | |
|---|---|---|---|---|---|
ABC Logistics | David Chen | Client | david@abclogistics.com | 1/15/2024 | |
International Trade Association | Sarah Johnson | Member | sarah@ita.org | 2/20/2024 | |
Red Flag Risk Assessment Matrix
Very Low Risk | Low Risk | Medium Risk | High Risk | Critical Risk | |
|---|---|---|---|---|---|
Ownership Transparency | |||||
PEP/Sanctions Risk | |||||
Litigation History | |||||
Financial Stability | |||||
Operational Transparency | |||||
Compliance Culture |
Does this entity require enhanced ongoing monitoring?
This final section requires formal approval from compliance and legal leadership. All risk factors must be acknowledged and appropriate mitigation measures documented.
Overall Risk Classification Recommendation
Low Risk - Standard Monitoring
Medium Risk - Enhanced Monitoring
High Risk - Enhanced Monitoring with Restrictions
Critical Risk - Requires Board Approval
Summary of Key Risk Factors and Mitigation Measures
Chief Compliance Officer Review Date
Chief Compliance Officer Approval
Chief Compliance Officer Digital Signature
Legal Counsel Review Required?
Legal Counsel Approval
Special Conditions or Restrictions on Engagement
Re-Assessment Frequency
Quarterly
Semi-Annually
Annually
Biennially
Upon Trigger Event
I acknowledge that continuous monitoring will be conducted throughout the engagement period
I certify that all information provided is accurate and complete to the best of my knowledge
Final Submission Date & Time