The greatest risk in crude re-export is not market volatility, but regulatory non-compliance. SNSUC’s screening script enforces a hard rule for Urals: every transaction must submit three documents — invoice, bill of lading, and payment proof — all confirming adherence to the G7-imposed $60/bbl price cap on Russian crude. If any one document is missing, the system blocks the transaction outright, preventing entry into the quotation process.

Origin classification must be precise. Iran is currently the sole country on the auto-rejection list — this is an absolute rule with no exceptions. Iraq’s exemption status has not been confirmed by any SNSUC-authorized source (JODI, IMF PortWatch, or public market data feeds); therefore, it must not be described as ‘explicitly exempt’ or assigned a specific effective date. Historically, Iran and Iraq were erroneously listed together as auto-rejected origins — a repeated error. Current red-line guidance prohibits joint listing of the two countries and forbids any definitive assertion of Iraqi exemption.

SOMO’s letters of credit follow a dedicated protocol: the beneficiary must be the Central Bank of Iraq (CBIRQAXXX), and payments must be irrevocably routed to the IRAQ OIL PROCEEDS account at the Federal Reserve Bank of New York — overriding any conflicting instructions on commercial invoices. The discharge port must be pre-locked as an STS anchorage structure prior to LC issuance; post-issuance port changes are strictly prohibited.

Operationally, the compliance officer reviews only three items before release: completeness of the three documents, compliance with the $60/bbl cap, and whether the origin is Iran. Only upon passing all three checks does the transaction proceed to foreign exchange locking and vessel chartering — speed is never prioritized over verification.