Case status: Active and confidential. Counterparty clearance remained on hold at the information date.
An overseas buyer was considering a high-value cross-border purchase of scrap metal from a Kenyan supplier. Before committing approximately USD 1 million or making an advance payment, the buyer instructed Raven Africa to test the counterparty’s legal identity, ownership, tax standing, operating footprint, licences, export authority, adverse information and capacity to perform.
The investigation confirmed that the counterparty existed in official company and tax records. It also identified material inconsistencies and unresolved controls that prevented safe transaction clearance.
Company registration confirms that a legal record exists. It does not prove ownership of the goods, a licensed operating yard, authority to export, delivery capacity or the safety of an advance payment.
The Client’s Question
The instruction was not limited to confirming incorporation. The client needed an independent answer to a wider commercial question:
Did the proposed Kenyan supplier have the identity, authority, licensed operating capacity, stock, tax standing and transaction history required to safely perform a USD 1 million scrap-metal contract?
The mandate combined corporate due diligence in Kenya, corporate intelligence, company-record verification, regulatory review, adverse-information research and field verification.
Investigation Process
Company and Ownership Verification
Obtained an official company search and checked the exact legal name, incorporation status, company number, registered office, director and shareholder particulars.
Tax and Document Authentication
Reviewed the company PIN, income-tax obligation, electronic-invoicing registration and Tax Compliance Certificate against KRA system results.
Address and Physical Verification
Compared registry, tax and public-facing addresses and conducted a field visit to the location presented to prospective buyers.
Licensing and Export Checks
Assessed whether current scrap-metal dealer licensing, licensed premises and shipment-specific export authority could be independently confirmed.
Adverse and Reputation Intelligence
Reviewed official warnings, historical non-delivery indicators, online business claims, litigation indicators and the public trading footprint.
Transaction-Control Review
Assessed banking alignment, representative authority, shipment evidence, advance-payment exposure and safer settlement structures.
Principal Findings
1. Legal existence was confirmed, but identity required reconciliation
The official registry confirmed a Kenyan private company. However, the exact registered name differed from the version used in public trading materials. For a high-value transaction, the name on the contract, invoice, beneficiary account and export documents should align with the official entity record.
2. The advertised operating footprint was not established
The registered office, tax address and public-facing trade address were inconsistent. A visit to the address presented to buyers did not identify a scrap yard or visible scrap-storage or processing operation.
This did not prove that no facility existed elsewhere. It meant that the actual licensed yard, legal occupation of the premises, stock ownership and loading capacity remained unverified.
3. Tax registration did not amount to current transaction clearance
The company PIN appeared active, and the entity was registered for company income tax. Electronic-invoicing registration appeared inactive. A live Tax Compliance Certificate check also returned an expired status that conflicted with the certificate presented for review.
Inactive eTIMS or TIMS status is a material compliance and activity indicator for a business expected to issue taxable invoices, but it is not conclusive proof that the company is not trading or has failed to pay tax.
4. A material Tax Compliance Certificate conflict required escalation
The live KRA checker result conflicted with the certificate supplied to the reviewer. The discrepancy was not treated as proof of forgery. It did mean that the presented certificate could not safely be relied upon without direct KRA clarification and a newly validated certificate.
5. Scrap-metal licensing and export authority remained unverified
No current dealer licence, licensed-premises confirmation or consignment-specific export authority was independently verified during the initial review. These were fundamental information gaps because lawful dealing, possession, loading and export of the material formed the basis of the proposed performance.
6. Adverse information was directly relevant to advance-payment risk
An official diplomatic advisory warned overseas buyers about reported scrap-metal non-delivery schemes involving advance payments and included the reviewed counterparty among entities reported to the issuing mission. A separate historical anti-fraud database carried a non-delivery classification linked to the same public-facing identity.
Evidentiary caution: The official advisory recorded reports received, and the independent database was a risk lead. Neither source was presented as a Kenyan court judgment, criminal conviction or adjudicated finding against the counterparty or its personnel. The reported pattern was nevertheless closely relevant to the proposed transaction and carried substantial risk weight.
7. Banking and performance capacity were not verified
No beneficiary account had been independently confirmed, and the reviewed evidence did not establish stock ownership, completed shipment history or the financial capacity to perform a transaction of the proposed size.
Consolidated Risk Assessment
| Risk domain | Rating | Basis | Required control |
|---|---|---|---|
| Legal existence | Low | Official incorporation record confirmed. | Use the exact legal name and company number. |
| Identity consistency | High | Name, address and contact details required reconciliation. | Align registry, KRA, bank, contract and export records. |
| Operating footprint | High | No yard was identified at the public-facing address. | Visit the actual licensed yard and verify stock and capacity. |
| Tax compliance | High | Inactive electronic invoicing and a conflicting expired TCC result. | Obtain a current KRA-validated TCC and written explanation. |
| Sector regulation | High | Dealer licence, licensed premises and export approval were unverified. | Obtain direct regulatory and consignment-specific confirmation. |
| Adverse information | Critical | Official reported warning and historical non-delivery indicator. | No unsecured advance; enhanced verification and secured settlement. |
| Banking and payment | Unknown | The proposed beneficiary account was not independently verified. | Confirm the exact corporate beneficiary directly with the bank. |
| Performance capacity | Unknown | Stock ownership and shipment capacity were not established. | Verify title to stock, customs records and buyer references. |
Ratings describe transaction risk at the information date. They are not findings of criminal liability.
Transaction Position and Recommended Controls
Overall position: High risk, with a critical adverse-information component.
Raven advised the client not to make an unsecured advance payment and not to treat the counterparty as cleared. Any further consideration of the transaction was made conditional on cumulative controls:
- Direct confirmation of the dealer licence, licensed premises and eligibility to export the proposed material.
- Independent verification of the shipment-specific export authorisation or consignment certificate.
- A fresh visit to the actual licensed yard, including evidence of legal occupation, stock ownership and loading capacity.
- A current KRA-validated Tax Compliance Certificate and an explanation of the electronic-invoicing status.
- Direct confirmation that the beneficiary was a Kenyan corporate account in the exact registered legal name.
- Director-signed authority for every representative handling the contract, invoice or payment instructions.
- Verifiable bills of lading, customs records, shipping-line confirmation and independently contacted overseas buyers.
- A controlled payment structure, such as confirmed documentary credit or reputable escrow, rather than unsecured advance transfer.
- A contract with title-to-goods warranties, regulatory representations, inspection rights, refund obligations, dispute resolution and fraud or misrepresentation remedies.
Why the Intelligence Mattered
The review moved the transaction decision away from surface-level documents, websites and warehouse representations toward independently verifiable facts.
Legal Existence Is Only the Start
Registration does not establish solvency, stock ownership, operating capacity or delivery history.
Tax Registration Is Not Clearance
An active PIN does not replace current certificate authentication and electronic-invoicing checks.
A Site Visit Needs Verification
Seeing goods does not prove title, licensing of the premises or authority to export the consignment.
For a transaction of this size, enhanced due diligence is a transaction-control process. The counterparty, goods, premises, licences, bank account, documents and payment structure must all align before commitment.
Confidentiality and Evidentiary Note
This public case study is anonymised. The client, target, directors, contacts, tax identifiers, account information, source documents and sensitive operational evidence are withheld.
The case remained active at the information date. No allegation is presented as an adjudicated finding. The purpose of this page is to explain Raven Africa’s methodology and decision value without disclosing confidential instructions or prejudicing any party.
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