Tank‑Storage & Fuel‑Paper Scams: Legal Overview & Red‑Flag Checklist
1. Executive Brief
Every email promising “JP54/EN590 allocations” at USD –10 to –25 per bbl versus Platts
is fraud—no exceptions, no edge cases. Real barrels are either pre‑financed or sold at a premium through established channels. The blast comes from bot‑farm domains; the attached paperwork is forged; the discount is economically impossible. Anyone forwarding the offer is propagating a confidence scheme and stepping into civil and criminal liability.
2. Modus Operandi
- Bot‑Farm Outreach.
Scraped contact lists from LinkedIn, shipping databases, and dissolved‑company filings fuel mass mailings.
- Forgery Stack.
Fake tank receipts, inspection certificates, and POP letters reuse logos and signatures lifted from public filings.
- Broker‑Chain Bloat.
NCNDA/IMFPA chains promise USD 1‑3 per barrel to each “agent,” creating a make‑believe margin that hides the absence of product.
- Up‑Front Money Trigger.
“Performance bond,” “tank activation fee,” or “inspection cost” is routed to shell fintech accounts and disappears.
- Infinite Delay Loop.
Ghost excuses (port congestion, customs audit) extract successive fees until victims walk or litigate.
3. Economic Impossibility
Refined‑product economics kill the discount story on sight:
- Borrow‑Base Controls.
Banks financing refinery runs track collateral daily; dumping barrels below market breaches loan covenants instantly.
- Hedging Discipline.
Majors lock crack spreads via swaps. Selling at a loss triggers margin calls they will not accept.
- Storage Scarcity.
Rotterdam, Houston, Fujairah tanks are forward‑booked. A stranger cannot “slide one million barrels” into a phantom tank next week.
4. Liability Exposure for Intermediaries
- Fraud by False Representation.
Forwarding forged docs triggers criminal liability even if you never handle funds.
- Unlicensed Commodity Brokerage.
Soliciting or arranging these deals without regulatory permission violates SEC, FCA, and ESMA rules.
- Sanctions & AML Breaches.
Many offers trace to embargoed jurisdictions. Engaging equals sanctions exposure.
- Civil Claims.
Burned counterparties sue every broker in the chain for negligent misstatement and unjust enrichment.
5. Red‑Flag Indicators (Meaning: Every Offer You’ll See)
- Generic bulletins: “2 M bbl EN590, FOB Rotterdam.” No laycan, no parcel schedule, no charter‑party.
- Exotic payment instruments: unrated banks issuing MT760 SBLCs against supposed Tier‑1 storage.
- 48‑hour pressure: “Sign or allocation reallocates.” Legit trades require full KYC and vessel vetting.
- Broker chains stacking USD > 5 per barrel in aggregate commissions.
- Entity‑location mismatch: Belize LLC “owns” product in CLH Spain; Panama trust “controls” tanks in Houston.
Receiving one of these emails? Don’t fantasise about “risk‑free USD 2 spreads.” Forward it to our fraud desk. We trace IP strings, verify tank numbers, and name the shell entities before you become another line item in a prosecutor’s exhibit list.
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Financely Group provides advisory services on commodity‑fraud risk. We are not a deposit‑taking bank and do not hold client funds unless a regulated custodian is appointed. Any transaction in refined products is subject to KYC, sanctions screening, and compliance with UCP 600, ISBP 745, and applicable national regulations. This note is for information purposes only and does not constitute legal advice or an offer to transact.