Trade Payment & Finance Risk Mitigation

Compliance Due Diligence

May 12, 2009

Wisconsin International Trade Conference

Trade Payment and Finance Risk Mitigation

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Presenter:

Tom Gaglione

Global Trade Services

414-977-6733

Selling_Trade_Svcs_v1.ppt

22STRICTLY PRIVATE AND CONFIDNTIAL © 2007 JPMorgan Chase & Co. All rights reserved. JPMorgan Chase Bank, N.A. Member FDICSTRICTLY PRIVATE AND CONFIDNTIAL © 2007 JPMorgan Chase & Co. All rights reserved. JPMorgan Chase Bank, N.A. Member FDIC

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approach to risk management

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GLOBAL COVERAGEGLOBAL COVERAGE

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Optimize Trade Flow and Investment Returns

0



Global Presence & Reach

ArgentinaBuenos Aires

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CanadaCalgaryMontrealTorontoVancouver

Cayman IslandsGeorgetown

ChileSantiago

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United StatesChicagoDallasLos Angeles New YorkSan Francisco Tampa

VenezuelaCaracas

Americas Austria

Vienna

BelgiumBrussels

Channel IslandsJersey

Czech RepublicPrague

FranceParis

GermanyBerlinFrankfurtMunich

GreecePiraeus

IrelandDublin

ItalyMilanRome

Luxembourg

NetherlandsAmsterdam

NorwayOslo

PolandWarsaw

PortugalLisbon

RussianFederationMoscow

SpainBarcelonaBilbaoMadridPamplonaSevilleValencia

SwedenStockholm

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United KingdomBournemouthEdinburghGlasgowIsle of ManLondon

Europe Egypt

Cairo

NigeriaLagos

South AfricaCape TownJohannesburgPietermaritzburg

AfricaAustraliaAdelaideBrisbaneBuderimCanberraGold CoastMelbournePerthSydney

BahrainManama

China BeijingHong KongShanghai

China (cont’d)ShenzhenTianjin

IndiaMumbaiNew Delhi

IndonesiaJakarta

Iraq Baghdad

IsraelTel Aviv

JapanOsakaTokyo

LebanonBeirut

MalaysiaKuala LumpurLabuanSelangor

New ZealandAuckland

PakistanKarachi

PhilippinesManila

Singapore

South KoreaSeoul

TaiwanPan Chiao CityTaipei

ThailandBangkok

TurkeyIstanbul

UzbekistanTashkent

VietnamHanoiHo Chi Minh City

Sri LankaColombo

Middle East/ Asia Pacific



Compliance Due Diligence

Compliance: Yield to, follow a wish, request, demand.

- aka; Requirements and Process

Diligence: Attentive care / Painstaking effort

- i.e. the Devil is in the Details



Global Trade Risks

Payment Risks

- Commercial

- Political

Regulatory and Counter Party Risk

- Trade Compliance

- Supply Chain Parties

Reputational Risk

- Good Name and Image



Methods of Payment

Exporter’s uncertainty

increases

• Cash in Advance

• Letter of Credit• Confirmed

• Advised

• Documentary Collections• D/P

• D/A

• Open Account

Importer’s

uncertaintyincreases



Letters of Credit

Tried and True Payment Risk Mitigation Tool

Ship and Comply with ALL LC Conditions = Payment Assurance

Strong Widely Applied Governing Rules and Case Law

___________________________________

Costly and Expensive Instrument !

Onerous to Structure and Use !



Letters of Credit - Cost

Consider the Benefit to Risk Proposition:

Reputable bank promise to pay If confirmed, a U.S. bank promise to pay

vs

Cost of loss of shipment value / margin

Plus cost of collection agencies or legal costs

Plus cost of time and productivity lost

Plus Opportunity Cost related to more productive pursuits



Letters of Credit – Structure & Use

Take Charge of the Process !!

Seek Assistance and Ask Questions Upfront with your bank

Use Letter of Credit Guide Tool - and then Template

Minimize / Eliminate the Complications and Balkiness

Optimize Cash Flow

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Guide for Requesting a Letter of Credit

PLEASE INSTRUCT YOUR BANK TO OPEN AN IRREVOCABLE LETTER OF CREDIT SUBJECT TO THE UNIFORM CUSTOMS AND PRACTICE FOR DOCUMENTARY CREDITS, INTERNATIONAL CHAMBER OF COMMERCE PUBLICATION 600 AND IN ACCORDANCE WITH THE FOLLOWING TERMS AND CONDITIONS:

BENEFICIARY: (NAME AND ADDRESS AS YOUR INVOICE WILL BE TITLED)

______________________________________________________________

PROFORMA INVOICE NO: _______________________ PROFORMA INV. DATE: ________

YOUR ORDER NO: ______________________________ YOUR ORDER DATE: ____________

AMOUNT: _________________________ CURRENCY: ____________________

MERCHANDISE DESCRIPTION (provide a brief description, omit unnecessary details):

______________________________________________________________

LETTER OF CREDIT SHOULD BE ADVISED THROUGH:

JPMORGAN CHASE BANK, N.A.

GLOBAL TRADE SERVICES – Mail Code: IL1-0236

300 South Riverside Plaza, 2nd Floor

Chicago, Illinois 60606

SWIFT: CHASUS33 TELEX: ITT 420120 CMBUI

AVAILABILITY:L/C MUST BE AVAILABLE (BY PAYMENT, ACCEPTANCE OR NEGOTIATION AS APPLICABLE) AT THE COUNTERS OF JPMORGAN CHASE, OR BE FREELY NEGOTIABLE BY ANY BANK AND PROVIDE REIMBURSEMENT INSTRUCTIONS.

PARTIAL SHIPMENTS: ALLOWED NOT ALLOWED

CONFIRMATION: ADD CONFIRMATION DO NOT ADD CONFIRMATION

If a confirmation is requested, such confirmation should be issued by JPMorgan Chase.

EXPIRATION DATE: __________ OR _______ DAYS AFTER DATE OF ISSUANCE

SHIPMENT DATE: __________ OR _______ DAYS AFTER DATE OF ISSUANCE

TENOR OF DRAFT: SIGHT _____DAYS AFTER SIGHT

_____DAYS AFTER BILL OF LADING DATE

PRESENTATION: PRESENTATION OF DOCUMENTS WITHIN_____ DAYS AFTER SHIPPING DATE. (NOTE: PLEASE DO NOT USE THE WORD “STALE” IF YOU NEED MORE THAN 21 DAYS FOR PRESENTATION OF DOCUMENTS. REQUEST L/C TO

READ: DOCUMENTS PRESENTED IN EXCESS OF 21 DAYS ARE ACCEPTABLE.

CREDIT MUST BE ISSUED BY: SWIFT TELEX COURIER MAIL3



Guide for Requesting a Letter of Credit

SHIPPING TERMS: EXW FCA FAS FOB

(OCEAN ONLY)

CFR CIF CPT CIP

NAMED PLACE / PORT /AIRPORT______________________________

OTHER: __________________________________________________________________________________

DOCUMENTS REQUIRED:

COMMERCIAL INVOICE_____ORIGINAL (S)_____COPY (IES)

PACKING LIST _____ORIGINAL (S)_____COPY (IES)

INSURANCE POLICY/CERTIFICATE COVERING ALL RISKS (SPECIFY ANY ADDITIONAL RISKS, WHICH ARE TO BE COVERED IF ANY):________________________________________________________

TRANSPORT DOCUMENTS:

MARINE BILL OF LADING____“CONSIGNED TO” OR____”CONSIGNED TO THE ORDER OF”:

______________________________________________________________________________________

MULTIMODAL TRANSPORT DOCUMENT____”CONSIGNED TO” OR____”CONSIGNED TO THE ORDER OF”: ______________________________________________________________________________

AIR WAYBILL CONSIGNED TO: ___________________________________________________________

TRUCK BILL OF LADING CONSIGNED TO: ______________________________________________

OTHER TRANSPORT DOCUMENTS: __________________________________________________________

TRANSPORT DOCUMENTS MUST SHOW SHIPMENT

FROM________________________________TO__________________________________AND BE MARKED: _____FREIGHT COLLECT OR ________FREIGHT PREPAID AND NOTIFY (NAME AND ADDRESS): __________________________________________________________________________________________

OTHER DOCUMENTS (IF ANY):__________________________________________________________________

FOR TRANSFERABLE L/Cs: L/C MUST STATE THAT IT IS TRANSFERRABLE AND TRANSFERS, IF ANY ARE RESTRICTED TO THE ADVISING BANK.

BANK CHARGES: ISSUING BANK CHARGES ARE FOR THE ACCOUNT OF APPLICANT. BANK CHARGES OTHER THAN THOSE OF THE ISSUING BANK (ADVISING, CONFIRMATION, PAYMENT, ETC) ARE FOR THE ACCOUNT OF_______APPLICANT OR________BENEFICIARY.

DISCOUNT CHARGES: IF APPLICABLE, ARE FOR THE ACCOUNT OF______APPLICANT OR______BENEFICIARY

OTHER SPECIAL INSTRUCTIONS: __________________________________________________________

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Letter of Credit Checklist

Upon receipt of the letter of credit, read it in its entirety and check the following:

Buyer _________________________________

Purchase Order No. _____________ or

Pro Forma Invoice No. ___________ dated _________________

L/C No. _________________________

Date Received __________________[ ] Preadvised by phone

TERMS TO CHECK

Letter of Credit is [ ] Irrevocable [ ] Revocable

Letter of Credit has been [ ] Advised [ ] Confirmed

Beneficiary’s name and address [ ] OK [ ] NO

Amount sufficient to cover costs [ ] OK [ ] NO

Price, Quantity, good description [ ] OK [ ] NO

Expiry Date [ ] OK [ ] NO

Latest Shipment Date [ ] OK [ ] NO

Terms of the Draft [ ] Sight [ ] Time (Usance/terms)

U. S. bank charges [ ] Buyer [ ] Seller

SHIPPING INSTRUCTIONS

Export License needed [ ] YES [ ] NO

Need documents legalized [ ] YES [ ] NO

Partial Shipments [ ] Allowed [ ] Prohibited

Transshipments [ ] Allowed [ ] Prohibited

Shipment via [ ] Ocean [ ] Air

Shipment terms [ ] FOB [ ] FCA [ ] FAS [ ] CFR [ ] CPT [ ] CIF [ ] CIP [ ] EXW

Shipment from __________________________ to ______________________________

Consigned to ____________________________________________________________

Shipping Marks ____________________________________________________________

Bank to present documents to _________________________________________________

Copy of Letter of Credit to be sent to:

[ ] Freight Forwarder [ ] Traffic Department

[ ] Credit Department [ ] Sales Department



Common LC Discrepancies

DRAFTS

Drawn on the wrong party

Tenor (sight/time) is incorrect

Not properly signed and/or endorsed

Amount differs from what is indicated on the invoice

Amount differs in words and numbers

Letter of Credit number and issuing bank’s name are missing

Drawn on statement not per letter of credit

COMMERCIAL INVOICE

Description of goods not exactly as per the letter of credit

L/C amount exceeded. Excess quantity shipped

Partial shipment effected (when prohibited)

Shipping terms not stated, or inconsistent with the letter of credit

Packages listed as cartons, are described as cases on the bill of lading (inconsistency)

Goods shipped not required under the letter of credit (i.e. samples at no charge)

The amount of freight charges, if shown separately, differs from that shown on the transport document

Includes unauthorized charges, (i.e. handling and documentation charges in addition to FOB vessel/FCA airport terms

Not signed/not visaed by Chamber of Commerce or not legalized (when required).

MARINE BILL OF LADING

Unclean bill of lading presented (i.e. expressly declares a defective condition of the goods/ and or of the packaging

No evidence of goods actually shipped or loaded on board a named vessel (i.e. notation is not dated or signed)

Shipment made between ports other than those specified in the letter of credit

Issued or endorsed to the wrong party

Notify party and consignee not per letter of credit requirement

Bill of lading issued by forwarding agent

Transshipment effected (when prohibited)

Late Shipment



Common LC Discrepancies

AIR WAYBILL

Evidences unauthorized charges to be collected from consignee contrary to shipping terms (i.e. handling, documentation, cartage, insurance)

Shipment made between airports other than those on the letter of credit

Not signed by carrier, or his agent, does not bear the reception stamp of the carrier or his agent

Does not include flight date and/or flight number

INSURANCE DOCUMENT

Goods are under-insured

An insurance certificate was presented when credit calls for an insurance policy

Does not identify with goods shipped (i.e. missing shipping marks, number of shipping units, weights, etc.)

Dated after the date of shipment, and no evidence that coverage is effective at the latest date from shipment

Not endorsed or countersigned

Not all originals presented or accounted for

Insurance risks covered not as specified on the letter of credit

GENERAL

Late presentation

Letter of Credit expired

Partial shipment effected when the letter of credit prohibits it

Documents inconsistent with one another (i.e. shipping marks, weights, quantities differ)

Beneficiary’s name/address not per the letter of credit

Applicant’s name/address not per the letter of credit

Absence of documents called for in the letter of credit

Absence of signatures on documents, when required



Incoterms 2000

Beneficiary

(Seller)

Applicant

(Buyer)

EXW

FCA

FAS

FOB

DAF

DES

DEQ

DDU

DDP

CFR

CIF

CPT

CIPDock of

Exportation

Dock of

Importation

Transportation

to DockTransportation

to BuyerImport

Duty

Loading

onto

Vessel

Ocean

Freight

Marine

InsuranceUnloading

ChargesLoading

onto

Vessel

Ocean

Freight

Marine

Insurance

Unloading

Charges



Documentary Collection

Defined as the process by which a bank known as the Remitting Bank, acting upon the instructions of an exporter, presents documents associated with an export transaction to the importer.

This is done with the assistance of a second bank, known as the Collecting Bank. Documents typically consist of one financial instrument (Bill of Exchange or Draft) and multiple commercial (invoice, bill of lading, etc) documents.

• Banks involved have NO OBLIGATION to pay, however…• Bank acting as collection agent can be effective• Protesting a defaulted draft can have significant legal impact• Signed Draft enhances legal position vs. general creditors



Credit Insurance Due Diligence

A trade credit insurance policy generally differs from most types of property/casualty policies in that it requires ongoing maintenance. So, unfortunately, you can not just file it away and only refer to it when a loss occurs. Here are some of the typical requirements and responsibilities you need to be aware of in order to make certain you are in compliance with your specific policy.

Policy Declarations - Be certain you know and understand these features of your policy:

Policy inception date and expiration date

Policy limit – maximum amount insurer will pay out in claims per policy period

Coinsurance – percentage of each loss that you retain/insurer doesn’t cover

Deductible – annual first loss dollar amount, usually per policy period

Premium – amount due, when, and how calculated

Specific products and/or services to be insured

Maximum payment terms allowed

Any specific exclusions (countries, payment terms, buyers)

Country waiting period – time frame before claims may be filed or paid

Claim filing window – earliest and latest dates claims may be filed

Buyer and Credit Limit Approvals – Know how approvals are made and who grants them:

Who approves buyers and limits, you or the insurance company?

Credit information is required for approvals

Credit limit approved for each buyer intended for insurance

Credit limit still operative – has not been reduced or cancelled

Credit limit sufficient to cover highest amount of outstanding invoices

Payment terms same or less than policy maximum; any special conditions

Invoices are sent to buyer’s legal name and address specified on approval

Reporting Requirements – Know what you have to do and when:

Report past due invoices, usually at 60 days overdue for amounts over $10,000; continue reporting until invoice is paid or a claim is filed; if none, report “none”

Notify insurer immediately if buyer asks for an extension of past due invoice

Notify insurer immediately (within 10 days of receipt) of any buyer bankruptcy or preference payment notices



Credit Insurance Due Diligence

Annual Policy Renewal – Plan to begin renewal at least 2 months before your policy expires:

Review buyer credit limits; indicate any that need increases, reductions, or cancellation

Pay invoice for additional premium due, if applicable

Complete and submit renewal application and requested information

Review new policy quote

If acceptable, acknowledge and sign quotation; pay new premium invoice

Review all policy documents, endorsements and policy text

Claim Filing Documents

Keep copies of correspondence with buyer concerning past due invoices and/or product disputes or warranty issues

Complete insurer’s Proof of Loss form

Typical documents required: Purchase order/proforma invoice, commercial invoice, evidence of shipment to buyer, buyer’s acknowledgment of receipt of product in good condition, written demand for payment of past due invoice and any other collection efforts

MISTAKES TO AVOID!

Unfortunately, some claims are denied because the insurance policyholder failed to do something required under the Policy. Please help us to help you avoid these mistakes. Here are four common reasons that multi-buyer insurance claims are not paid.

LATE CLAIM FILINGS – In order to be paid in full under the Policy, you must file your claim on time. Know your claim filing deadline!

LACK OF PROOF OF EXPORT OR SHIPMENT – You must have shipping documents that show that the items you sold were shipped to the buyer who ordered them.

VIOLATING BUYER CREDIT TERMS – Be certain you did not extend payment terms longer than your approval states or failed to follow any special conditions approved for that buyer.

FAILURE TO STOP SHIPPING – Do not continue shipping new orders to buyer when: payments are over 60 or 90 days past due, credit limit has been reduced or cancelled, files bankruptcy, or other conditions as stated in your policy.

Please remember, you must read and understand your entire Policy – and especially read the endorsements! In order to get your claim paid, there are typically other conditions in the Policy that must be satisfied in addition to those mentioned here; these are just a few of the items that may cause denials of your claim. When in doubt, ask!



Global Trade Compliance Worksheet

JPMORGAN REF NO: ______________________ ITEM NO: ________________________

AMOUNT : ______________________ DATE: ________________________

REVIEWED BY : ______________________ SIGNATURE: ________________________

(Print Name) (Sign Name)

I HAVE REVIEWED THIS TRANSACTION IN ACCORDANCE WITH THE GLOBAL TRADE SERVICES AML POLICY AND PROCEDURES, GTS OFAC/BIS POLICY AND PROCEDURES, AND GTS ANTI-BOYCOTT POLICY AND PROCEDURES LOCATED IN THE QMS DATABASE.

OFAC Review

List all names (parties including locations, vessels, etc.) or attach a screen print of names scanned and initial applicable box (es) below:

______________________________________________________________________________________________________

□OFAC checked electronically □OFAC checked manually, no match found. □ Screen print attached.

□OFAC checked manually and escalated to Trade Risk Management/local compliance officer.

Note: If referred via the GTS Trade Compliance Mailbox attach a copy of the response to this form.

Anti-Boycott Review (Initial applicable box):

□ Reviewed for Boycott language and no Boycott language found.

□ Reviewed for Boycott language and escalated to GTS Risk Management/local compliance officer.

Note: If referred via the GTS Trade Compliance Mailbox attached a copy of the response to this form.

Anti-Money Laundering and Suspicious Activity Review (Initial applicable box):

(See reverse side for red flags and referral guidelines)

□Reviewed for suspicious activity and no referral required.

□Reviewed suspicious activity and escalated to Supervisor, Trade Risk Management or local compliance officer.

Note: If referred via the GTS Trade Compliance Mailbox attached a copy of the response to this form.

Supervisor and Trade Risk Management Use Only:

-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Name of Supervisor or Trade Risk Manager: _______________________ Date: __________________



“Red Flags” Reference Guide

All Transactions:

Refer the following concerns to Trade Risk Management or local compliance officer:

The structure of the transaction is overly complex.

Transaction does not "make sense" or looks too good to be true.

The apparent misuse of the trade product being requested.

Request to pay third party.

Insufficient, false or suspicious information provided by customer.

Refer the following concerns to your supervisor and escalate to Trade Risk Management, or local compliance officer if resolution cannot be reached:

The transaction is an offshore shipment (e.g. buyer/seller located in USA, while movement of goods occurred offshore of USA).

The amount appears to be extraordinarily large (as determined by the nature of the transaction and customer).

Inquiries are numerous, or there is a high of a sense of urgency for the transaction.

Customer appears inexperienced yet confident.

Transaction or parties in high-risk jurisdiction.

Sudden change in customer’s pattern of trade transactions.

Commercial and Standby Letters of Credit:

Refer the following concerns to Trade Risk Management or local compliance officer:

The merchandise or service provided is inconsistent with the nature of the customer's business.

The LC has been amended excessively, making the transaction overly complex.

Transaction is designed to evade home country legal restrictions.

The LC contains non-standard clauses, or phrases such as:

Request to issue a "ready, willing, and able" message, or a "Letter of Interest"; LC is "unconditional, divisible, and assignable”; transactions requiring “Proof of Product”; Funds are "good, clean and cleared, of non-criminal origin"; bearer instrument Letter of Credit; transferable and assignable without utilization; “Top 50 Prime International Banks” or similar language.

The merchandise description indicates equipment for military or police organizations of foreign governments, weapons, ammunition, controlled substances, chemical mixtures, classified defense articles or technical data. Such merchandise may require an export license.

Documents evidencing shipment locations or goods inconsistent with LC and/or customers usual and customary business.

Over or under pricing.

A drawing is received under Standby Letter of Credit shortly after issuance.

Middleman does not add value to the transaction.



“Red Flags” Reference Guide

Refer the following concerns to your supervisor and escalate to Trade Risk Management, or local compliance officer if resolution cannot be reached:

The LC to be advised should state the full name and address of the beneficiary, (not a P.O. Box). The LC does not state full merchandise description, only shows purchase order numbers or non-specific descriptions such as "general merchandise" or “ spare parts”.

The LC does not require a transport document or a forwarders cargo receipt.

The transport document does not match the transaction.

Applicant-issued documents called for in the letter of credit.

Transport document does not match the transaction. or consigned to a party other than applicant or issuing bank.

Beneficiary or Applicant refuses to provide documents to prove shipment of goods.

LC received as unauthenticated SWIFT or untested telex message.



Safe or Sorry ?

Export compliance will continue to remain one of the manufacturing world’s greatest challenges.

When things go wrong, the first and most problematic question asked by regulatory officials is “do you have a file describing the due diligence you performed before the export?

If the answer is no, the next steps can be expensive, time consuming, and reputation damaging

Key parts of a Compliance Program to avoid compliance failures ?



12 Steps to Effective Compliance Prog.

1. OBTAIN C-LEVEL MANAGEMENT AND BOARD COMMITMENT

2. ASSESS CURRENT PROCESS / PERFORM GAP ANALYSIS

3. KNOW / MAINTAIN LIST OF EMBARGOED COUNTRIES

4. SCREEN NAMES AND ADDRESSES (ELECTRONICALLY)

5. ESTABLISH ON-GOING SCREENING PROCESS

6. PERFORM END-USE AND DIVERSION RISK SCREENING



12 Steps to Effective Compliance Prog.

7. JURISDICTION & CLASSIFICATION INFO. FROM SUPPLIERS

8. PERFORM LICENSE DETERMINATION

9. DOCUMENT PROCEDURES FOR EACH BUSINESS FUNCTION

10. TRAIN, TRAIN !, TRAIN !!

11. FOLLOW ISO 9000 AND SARBANES-OXLEY STANDARDS

12. PERFORM AUDITS OF PROCEDURES EVERY YEAR



Trade Management Consulting

HELP!

USDOC – BIS (Bureau of Industry and Security)

Independent Trade Consulting Firms

Captive Trade Management Practices of Large Service Firms

Law Firms

Accounting Firms

Freight Forwarders

Scale, Volume, and Complexity of your company’s Trade Flows and Trade Lanes will determine best fit



ON DEMAND Trade Consulting

On Demand Consulting Service is a subscription based service with a minimum commitment of 80 hours of export or import service over 1 year.

Designed to give companies the flexibility to engage – quickly – trade management consulting expertise to address a wide range of export, import compliance and/or supply chain issues

Service augments a company’s current resources and helps companies understand the export or import requirements as they apply to their business, and also can supplement the company’s management of their compliance operations on a day-to-day basis

Can be used to get started or as an on-going expertise resource



Standard “On Demand” Operational Compliance Services

Imports HTSUS Classification

Country of Origin Determination– CBP marking requirements– End Use / End User Review

Free Trade Agreement Management

Valuation– Accuracy of declarations– Additions and deductions– Filing of adjustments with CBP

Broker Management– Audit of import documentation and broker

invoices– Performance measurements

Exports Jurisdiction Determination

Department of Commerce (EAR) or

Department of State (ITAR)

Export Classification ECCN/USML HTS

Export Order Review Restricted Party Screening (RPS)

and resolution License Determination End Use / End User Review

Auditing of Export Documentation

And other trade compliance related services and support as And other trade compliance related services and support as requested by clients (e.g. development of import/export requested by clients (e.g. development of import/export compliance manuals, desk-level work instructions, delivery compliance manuals, desk-level work instructions, delivery of training/education, etc.)of training/education, etc.)



Thank you!

Questions?

Tom Gaglione

Global Trade Services

414-977-6733

[email protected]

Trade Payment & Finance Risk Mitigation

Business

Transcript of Trade Payment & Finance Risk Mitigation