Introduction

to UCP 600
for Importers
 Global Transaction Services
Cash Management Trade Services and Finance Securities Services Fund Services

Introduction to UCP 600 for Importers

Victor Pena
Vice President
Americas Regional Trade Advisor
 “These materials are provided for educational and illustrative

purposes only and not as a solicitation by Citigroup for any

particular product or service.

Furthermore, although the information contained herein is

believed to be reliable, the following does not constitute legal

advice, and Citigroup makes no representation or warranty as to

the accuracy or completeness of any information contained

herein or otherwise provided by it.”

2
UCP 600 Understanding & Application

ƒ Review History & Process

ƒ Comparison with UCP 500

ƒ Overview of UCP 600 Articles

3
Review History & Process
¾ The UCP is the work of the ICC, a private international organization
founded in 1919.

¾ Remains, to date, the most successful set of private rules for trade
ever developed.

¾ UCP 600 – Sixth (6th) revision since it’s inception by the

International Chamber of Commerce in 1933

¾ Included review - ICC Opinions, Decisions, DOCDEX cases, legal

decisions, URR525, ISP98 and eUCP

4
 Review History & Process

ƒ *Seven Articles that have lead to nearly 60% of ICC Opinions are:

- Article 9 Liability of Issuing and Confirming Banks

- Article 13 Standard for Examination of Documents
- Article 14 Discrepant Documents and Notice
- Article 21 Unspecified Issuers of Contents of Documents
- Article 23 Marine/Ocean Bills of Lading
- Article 37 Commercial Invoices
- Article 48 Transferable Credits

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5
 Review History & Process

ƒ ICC National Committees were requested to vote on issues such as:

– “On its face”, “Reasonable time”, “Negotiation” - leave out or retain
– Introduction of new articles, splitting of others, “parties” or “banks”,
– Discounting of deferred payment undertakings”
– Degree of review for “inconsistency” or “non conflicting”

ƒ ICC unanimously approved 2007 Revision on 25th October 2006

ƒ Effective July 1, 2007

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6
Comparison with UCP 500

¾ New terminology, concepts & wording introduced

¾ Re-organization of the rules
¾ Substantive & cosmetic changes
¾ Improved clarity, yet created new ambiguity

What’s not
changed …
Irrevocable
Irrevocable

Independent
Independent Documentary
Documentary

7
Comparison with UCP 500

UCP 600 (39 Articles) UCP 500 (49 Articles)

ƒ New: ƒ Not included in new

– Article 2 Definitions Revision:
– Article 3 Interpretations – Article 5 Instructions to
– Article 9 Advising of Credits Issue/Amend Credits
& Amendments – Article 6 (part) Revocable
– Article 8 Revocation
– Article 12 Nomination
– Article 12 Incomplete or
– Article 15 Complying Unclear Instructions
Presentation – Article 38 Other Documents
– Article 17 Original Documents – Articles 2,6,9,10,20,21,22,
& Copies 30,31,33,35,36,46,47
content merged or
amalgamated

8
Comparison with UCP 500

No Change from UCP 500 legal status

ƒ Rules apply to LC by incorporation into the LC - not by

operation of the law
ƒ Rules may be overridden by express terms in the L/C
ƒ Rules are subject to interpretation by national courts

9
Overview of UCP 600 Articles

General Provisions and Definitions 1-5

Liabilities and Responsibilities 6 - 13

Examination of Documents 14 - 17

Documents 18 - 28

Miscellaneous Provisions 29 - 33

Disclaimers 34 - 37

Transferable Credit & Assignment 38 - 39

UCP 600 39 v. UCP 500 49

10
Overview of UCP 600 Article 1

Applicable when the credit expressly indicates that is subject to these

“rules” - (SWIFT changes have been made to bring in line).

Use of SWIFT:
40E: Applicable Rules
UCP LATEST VERSION

Use of telex or letter:

This credit is subject to the Uniform Customs and Practice

for Documentary Credits, 2007 Revision, ICC Publication
No. 600.

This credit is subject to UCP 600

11
 Overview of UCP 600 Article 1

“Binding on all parties unless modified or excluded by the terms of the L/C.”

Contrary to article 32 of the UCP, this credit remains

valid for subsequent installments despite any shipment
or drawing not made within the period allowed.

Sub-Article 28(c) does not apply.

Documents must not be dated earlier than the date of

the issuance of this credit.

12
 Overview of UCP 600 Article 2
NEW Article 2 – Definitions (UCP 500 - Part of Art. 2, 7, 9, & 10)

Certain terms are defined, so that they provide references when

such terms are used in the articles

A Advising bank H Honour

Applicant
I Issuing bank
B Banking day
N Negotiation
Beneficiary
Nominated bank
C Complying presentation
P Presentation
Confirmation
Presenter
Confirming bank
Credit

13
Overview of UCP 600 Article 2
„ Honour

For credit available by …

Ö Sight payment Pay at sight
Ö Deferred payment Incur deferred payment undertaking
Pay at maturity
Ö Acceptance Accept bill of exchange
Pay at maturity

„ Negotiation
– Purchase by the nominated bank of drafts (drawn on another bank)
and/or documents under a complying presentation,
– By advancing or agreeing to advance funds to beneficiary, on or
before the banking day on which reimbursement is due to the
nominated bank.

14
Overview of UCP 600 Article 2
Nominated Bank
„ The bank with which the credit is available, or any bank in the case of
a freely available credit

Issuing Issuing Advising Advising

Beneficiary
Bank Bank

Nominated Nominated Nominated

Bank Bank Bank

L/C available with Restricted L/C

any bank
Bank named
Any bank is a in the L/C
nominated bank

15
 Overview of UCP 600 Article 3

NEW Article 3 – Interpretations (UCP 500 - Art. 47 & part of Art. 2, 20, 46)

NEW f A credit is irrevocable even if no indication to that effect.

NEW f For determining maturity date, the words “from” and “after”
exclude the date mentioned (ISBP – 45,d)

30 days from shipment date = 30 days after shipment date

Shipment date: 1 AUG 2007 Maturity date: 31 AUG 2007

16
Overview of UCP 600 Article 3

„ For determining a period of shipment, the words “from” and “after” have
different meanings
– “From” includes the date mentioned
– “After” excludes the date mentioned

Shipment to be effected
from August 10th
= Earliest shipment date
is August 10th

Shipment to be effected
after August 10th
= Earliest shipment date
is August 11th

17
 Overview of UCP 600 Article 4
Article 4 - Credits v. Contracts (UCP 500 - Art. 3)

f Independence Principle - L/C is a separate transaction from the

underlying contract

NEW f Banks should discourage any attempt to include contract as integral

part of L/C

L/C
Discouraged ?? Contract No.123

Details as per Contract

No.123, which is
appended and forms an
integral part of the credit.

18
Overview of UCP 600 Article 5

Article 5 - Documents v. Goods/Services/Performance (UCP 500 - Art. 4)

f Banks deal with documents f In Credit operations all

and not with goods, services parties concerned deal with
or performances to which the documents, and not with
documents may relate. goods, services and/or
other performances to
which the documents may
relate. (UCP 500 Article 4)

19
Overview of UCP 600 Article 6
„ Expiry date
Ö Last day for presentation of documents

„ Place for presentation

– Bank with which the L/C is available, or
– Any bank, if the L/C is available with any bank, and
– Issuing bank

L/C available with any bank L/C available with Bank XYZ

Place for presentation

1. Any bank 1. Bank XYZ

2. Issuing bank 2. Issuing bank

20
Overview of UCP 600 Article 9
Article 9 - Advising of Credits and Amendments (UCP500 - Art.7, 11,b)

„ By advising an L/C, the advising bank signifies:

– Its without any undertaking to honour or negotiate
– It has satisfied itself as to the apparent authenticity of the L/C
or amendment
NEW – The advice accurately reflects the L/C’s terms and conditions

21
Overview of UCP 600 Article 10
Article 10 – Amendments (UCP500 - Art. 9,d)

„ Confirming bank must inform issuing bank of election not to

extend confirmation to an amendment and may advise
beneficiary of amendment without it’s confirmation

„ Partial acceptance = Notice of rejection

„ Disregard any provision that the amendment shall be in force unless

rejected by beneficiary within certain time NEW

„ Presentation that complies with the credit and not yet accepted amendment
– deemed to be beneficiary’s acceptance of the amendment

22
Overview of UCP 600 Article 12
Article 12 – Nomination (UCP500 - Art. 10,c)

„ Nomination does not obligate nominated bank to honour

NEW „ By nominating a bank to accept a draft or incur a deferred payment

undertaking, an issuing bank authorizes that nominated bank to
prepay or purchase a draft accepted or a deferred payment undertaking
incurred by that nominated bank

L/C Citibank N.A. is authorized to :

Available with 1. Incur a Deferred Payment

Citibank N.A. by Undertaking (“DPU”); and
deferred payment
2. “Prepay” its DPU (ie early
at 90 days after
date of shipment payment before maturity)

23
Overview of UCP 600 Article 14
Article 14 - Standard for Examination of Documents (UCP 500 - Art. 13, 21, 22)

f Must examine documents on their face to determine compliance

f Other than the commercial invoice, description of goods, services

or performance, may be stated in general terms

f Disregard documents not required by L/C and may be returned

f Disregard non-documentary condition

f Documents may be dated prior to issuance date of LC, but not

later than date of presentation

24
Overview of UCP 600 Article 14
„ UCP 500: Reasonable time, not to exceed SEVEN banking days
following the day of receipt of documents

„ UCP 600: Max. of FIVE banking days following day of presentation.

Not curtailed or affected by other events.

M Tu W Th F Sa S M Tu W

UCP 600 0 1 2 3 4 X X 5

UCP 500 0 1 2 3 4 X X 5 6 7

What is reasonable ?
25
Overview of UCP 600 Article 14
Presentation Period
„ Presentation including an original transport document must be made
not later than 21 calendar days after date of shipment
„ Transport document - Subject to Articles 19-25

Data Not Conflicting

„ Data in a document must not conflict with data in that
document, other stipulated documents or the L/C

26
Overview of UCP 600 Article 14
Unspecified Issuer or Content
„ Other than invoice, transport document or insurance document, banks will
accept the document if (1) its content appears to fulfill the function, and
(2) it complies with 14(d)
Example: L/C calls for Inspection Certificate

Inspection Inspection
Certificate Certificate
Goods have
Goods have been Goods are been inspected
inspected and are certified to be of and are certified
certified to be in Singapore origin. to be in order.
order.
Signed Signed Signed
Dated 1 AUG 2007 Dated 1 AUG 2007 Dated 1 AUG 2007
9 8 9

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Overview of UCP 600 Article 14
Addresses of Beneficiary & Applicant NEW

„ Need not be the same between stipulated documents & the credit; but
„ Must be within the same country as in the credit
„ Disregard contact details of beneficiary and applicant (fax, phone, email)
stated in the credit (ISBP 61)
„ However, if they form part of consignee and notify party details in
transport document, applicant’s contact details must be as stated in the
credit

28
Overview of UCP 600 Article 14
Shipper, Consignor, Transport Document Issuer
„ Shipper or consignor of goods indicated on any documents
need not be the L/C beneficiary, but must be consistent among
all documents

„ Transport document may be issued by party other than

NEW carrier/ owner/ master/ charterer, provided it meets the
requirements of articles 19, 20, 21, 22, 23 or 24

29
Overview of UCP 600 Article 16
Article 16 – Discrepant Documents, Waiver and Notice (UCP 500 – Art. 14,b,c,d,e)

„ Nominated/Confirming/Issuing bank may refuse to honour or

negotiate discrepant documents
„ Issuing bank, in its sole judgment approach applicant for waiver

„ Notice of refusal must be given no later than close of the fifth

banking day following day of presentation

„ After providing notice of refusal

NEW – The bank may return documents to presenter at any time

30
Overview of UCP 600 Article 16

„ Single Notice of Refusal must state:

– the bank is refusing to honour or negotiate,
– each discrepancy in respect of the refusal, and
– one of the following:

The bank is holding documents pending presenter’s further

instructions
The issuing bank is holding documents until it receives waiver
NEW from applicant and agrees to accept it, or receives further
instructions from presenter prior to agreeing to accept the waiver
The bank is returning the documents

NEW The bank is acting in accordance with instructions previously

received from the presenter

31
Overview of UCP 600 Article 17
Article 17 – Original Documents and Copies (UCP 500 - Art. 20,c,ii)

f At least one original must be presented

f Original Document = apparent original signature, mark, stamp or

label of issuer of the document

f Also an Original = written, typed, perforated or stamped by the

document issuer’s hand; or
on original stationery; or
states that it is original

f L/C requires copies of documents, either originals or copies is

acceptable

f Documents “in duplicate”, “in two fold” or “in two copies”,

presentation of at least one original and remaining number in
copies is acceptable.

32
Overview of UCP 600 Article 18
Article 18 – Commercial Invoice (UCP 500 - Art. 37)

„ Invoice amount in excess of L/C – May be accepted by the

nominated bank, but must not be honoured or negotiated in
excess of L/C amount

„ Issued by beneficiary, made out in the name of

applicant, and need not be signed (except as provided in
article 38 – Transferable L/C)

„ Description of goods, services or performance must correspond

with L/C description

„ Must be in the same currency as L/C NEW

33
Overview of UCP 600 – Transport Articles

UCP 600 UCP 500

19 Transport Document Covering At 26 Multimodal Transport Document
Least Two Different Modes of
Transport
20 Bill of Lading 23 Marine/Ocean Bill of Lading
21 Non-Negotiable Sea Waybill 24 Non-Negotiable Sea Waybill
22 Charter Party Bill of Lading 25 Charter Party Bill of Lading
23 Air Transport Document 27 Air Transport Document
24 Road, Rail or Inland Waterway 28 Road, Rail or Inland Waterway
Transport Documents Transport Documents
25 Courier Receipt, Post Receipt or 29 Courier and Post Receipts
Certificate of Posting

34
Overview of UCP 600 – Transport Articles

„ New SWIFT 700 fields for transport details:

44A Place of Taking in Charge/ Dispatch from …/

Place of Receipt

44E Port of Loading/ Airport of Departure

44F Port of Discharge/ Airport of Destination
44B Place of Final Destination/ For Transportation to …/
Place of Delivery

35
Overview of UCP 600 Article 19
Article 19 – Transport Documents Covering at Least Two
Different Modes of Transport (UCP500 - Art. 26)
„ Must appear to indicate name of carrier
„ Signed by carrier, master or named agent
„ If signed by agent, need to specify for whom - carrier or
master - it is signed

ABC Forwarders ABC Forwarders

600 9 600 9
As Agent As Agent
500 8 500 9
For Master For Master,
Takashi Yanagawa

36
Overview of UCP 600 Article 20 & 21
Article 20 – Bill of Lading (UCP500 – Art. 23)
Article 21 – Non-Negotiable Sea Waybill (UCP500 – Art. 24)
„ Must appear to indicate name of carrier

„ Signed by carrier, master or named agent

– If signed by master, name of master is not necessary

Master 600 9
500 9
„ If signed by agent, need to specify for whom,
carrier or master - it is signed

ABC Forwarders ABC Forwarders

600 9 600 9
As Agent
For Master
500
8 As Agent 500 9
For Master, John Doe

37
Overview of UCP 600 Article 22
Charter Party Bill of Lading (UCP500 – Art. 25)

„ B/L containing indication that it is subject to a charter

party
„ Signed by master, owner, charterer or named agent
– If signed by master, or owner, or charterer, their
names are not necessary

Master, Owner or Charterer 600 9

„ If signed by agent, need to specify for whom –master,

owner or charterer - it is signed

38
Overview of UCP 600 Article 22
Charter Party Bill of Lading (UCP500 – Art. 25)
„ Agent signing for owner or charterer must indicate name of
owner or charterer

ABC Forwarders ABC Forwarders

600 9 600 9
As Agent As Agent
For Owner, John Doe For Charterer, John Doe

ABC Forwarders
600 9
As Agent
For Master

39
Overview of UCP 600 Article 22

Charter Party Bill of Lading (UCP500 – Art. 25)

„ Port of discharge may be shown as a range of ports, or

NEW
geographical area, as stated in L/C (ISBP 106)
– e.g. L/C calls for shipment to Asian ports

40
Overview of UCP 600 Article 23
Article 23 – Air Transport Document (UCP500 – Art. 27)

„ Must appear to indicate name of carrier

„ Signed by carrier or named agent
„ If signed by agent, need to indicate that agent has signed for or on
behalf of carrier
„ Must indicate date of issuance, which will be deemed to
be the date of shipment, unless……….
„ Specific notation of actual date of shipment, even not
NEW called for in the credit, will be deemed to be the date of
shipment

41
Overview of UCP 600 Article 24
Road, Rail or Inland WaterwayTransport Documents
(UCP500 – Art. 28)

f For rail transport document:

NEW Ö If it does not identify the carrier, any signature or stamp
of railway company is accepted as being signed by the
carrier (ISBP – 172)
Ö Transport document marked “duplicate” is accepted as
an original
Ö Transport document will be accepted as original whether
marked as an original or not (also applicable to inland
waterway transport)

f Road transport document marked for consignor or shipper

NEW or bear no marking for whom the document has been
prepared – is the original

42
Overview of UCP 600 Article 28
Article 28 – Insurance Document and Coverage (UCP500 – Art. 34-36)

„ Insurance document – Insurance policy, insurance certificate or

declaration under open cover
„ Issued and signed by insurance company, underwriter or their
agents or their proxies
„ Signature by agent or proxy indicated as being for or on behalf
of insurance company or underwriter

Agent for By proxy for

ABC Insurance Co. Ltd.
ABC Insurance Co. Ltd. ABC Insurance Co. Ltd.

43
Overview of UCP 600 Article 28
Article 28 – Insurance Document and Coverage (UCP500 – Art. 34-36)

„ All originals must be presented, if the document indicates that more

than one original has been issued
„ Cover Note not acceptable
„ Insurance policy is acceptable in lieu of insurance certificate or
declaration under open cover
„ Issued no later than shipment date, or it appears from the document
that cover is effective from a date no later than shipment date

Insurance Policy
Insurance Policy Bill of
Bill Lading
of Lading
Effective
EffectiveDate
Date Shipped
ShippedOn
OnBoard
Board
1 AUG 2007
1 AUG 2007 1 AUG 2007
1 AUG 2007
Issued
Issuedon
on88AUG
AUG2007
2007 Issued
Issuedon
on11AUG
AUG2007
2007

44
Overview of UCP 600 Article 28
Article 28 – Insurance Document and Coverage (UCP500 – Art. 34-36)
„ Min. 110% of CIF or CIP value, if L/C does not indicate insurance
coverage required

„ If CIF or CIP value cannot be determined from documents – take the

greater of the following:
– Amount for which honour or negotiation is requested; or
– Gross invoice value of the goods

NEW „ Risks covered at least :

Place of taking in charge or Place of discharge or final

shipment destination

… as stated in the L/C

45
Overview of UCP 600 Article 28
Article 28 – Insurance Document and Coverage (UCP500 – Art. 34-36)

„ L/C should state type of insurance required and additional risks to be

covered
„ If L/C uses imprecise terms such as “usual risks” or “customary risks”,
bank will accept insurance document without regard to any risks not
covered
„ If L/C requires insurance against “all risks”, bank will accept
insurance document containing any “all risks” notation or clause,
without regard to any risks stated to be excluded

NEW

„ Insurance document may :

– Contain reference to any exclusion clause
– Indicate that cover is subject to franchise or excess
(deductible)

46
Overview of UCP 600 Article 31
Article 31 – Partial Drawings or Shipments (UCP 500 – Art. 40)

„ Partial drawings or shipments are allowed

„ Presentation of multiple sets of transport docs evidencing shipment on

the same means of conveyance (e.g. vessel, aircraft) from different
ports/places on different dates and for the same journey to the same
destination – not partial shipment
Port A B/L “A” AUG
AUG11
• Same vessel and voyage
• Same destination
B/L “B” AUG
AUG77 Port D
Port B
B/L “C” AUG
AUG99
Port C
AA BB CC = L/C quantity

„ Take latest of the shipment dates as date of shipment (Aug 9 in the

above example) (ISBP 89)

47
Overview of UCP 600 Article 31
NEW „ Presentation of multiple sets of transport docs evidencing shipment on
more than one means of conveyance within the same mode of transport
(e.g. shipment by truck) will be regarded as partial shipment, even if
shipped on the same day for the same destination (ISBP 89)
Partial Shipment
Truck A AUG
AUG11
Destination
AUG D
Truck B AUG11

Truck C AUG
AUG11 AA BB CC = L/C quantity

48
Overview of UCP 600 Article 37
Article 37 – Disclaimer for Acts of an Instructed Party
(UCP 500 – Art. 18)

f Bank instructing another bank to perform services is liable

for that bank’s charges

f Issuing bank is liable for charges that cannot be collected

or deducted from the proceeds

49
Overview of UCP 600 Article 38
Article 38 – Transferable Credits (UCP 500 - Art. 48)

NEW „ Transferable credit – An L/C may be made available by the transferring

bank to a second beneficiary

First
First Second
Second
Applicant
Applicant Beneficiary
Beneficiary Beneficiary
Beneficiary

1 2 3 4

Issuing Transferring (May be the

Bank Bank Issuing Bank)

1. L/C application 3. Request for transfer

2. Transferable credit 4. Transferred credit –
(Credit has been made available
to a second beneficiary)

50
Overview of UCP 600 Article 38
Article 38 – Transferable Credits (UCP 500 - Art. 48)

„ Transferred credit must accurately reflect the terms and conditions of the
credit, including confirmation …

„ Second beneficiary’s documents may be sent to issuing bank if first

beneficiary fails, on first demand, to:
– Present its invoice (and draft, if any), or
– Rectify discrepancies in its invoice (where such discrepancies did not
NEW exist in second bene’s invoice)

51
Overview of UCP 600 Article 38
Article 38 – Transferable Credits (UCP 500 - Art. 48)

NEW „ 38 (k): Second beneficiary’s documents must be presented to

transferring bank

B A

Second beneficiary’s documents

First beneficiary’s draft & invoice
Documents after substitution

52
Overview of UCP 600 Article 38
„ Bank not obligated to effect transfer
„ All charges relating to the transfer are for the account of first
beneficiary
„ If L/C allows partial drawings or shipments, it can be transferred in part
to more than one second beneficiary
„ Transferred L/C cannot be transferred to any subsequent beneficiary
„ Must determine the handling of subsequent amendments
„ Rejection of an amendment by one or more second beneficiary does
not invalidate the acceptance by any other second beneficiary
„ Allowable changes:
- credit amount - unit price - expiry date - period for presentation
- latest shipment date - percentage of insurance coverage
First beneficiary’s name may be substituted for that of the applicant
„ Honour or negotiation of transferred L/C may be in the second
beneficiary’s country

53
Overview of UCP 600 Articles
Article 7 – Issuing Bank Undertaking (UCP500 – part of Art. 9,a)

Article 8 – Confirming Bank Undertaking (UCP500 - 9,c and part of Art.9,b)

Article11 – Teletransmitted and Pre-Advised Credits and

Amendments (UCP 500 - Art. 11,a,c)
Article 13 – Bank to Bank Reimbursement Agreements (UCP500 - Art.19)

Article 15 – Complying Presentation NEW

Article 25 – Courier Receipt, Post Receipt or Certificate of Posting

(UCP 500 – Article 29)

Article 26 – “On Deck”, “Shipper’s Load and Count”, “Said by

Shipper to Contain” and Charges Additional to Freight
(UCP 500 – Art. 31,i,ii and Art. 33,d)

54
Overview of UCP 600 Articles

Article 27 – Clean Transport Document (UCP 500 – Art. 32)

Article 29 – Extension of Expiry Date or Last Day for Presentation
(UCP 500 – Art. 44)

Article 30 – Tolerance in Credit Amount, Quantity and Unit Prices

(UCP500 - Art. 39)

Article 32 – Installment Drawings or Shipments (UCP 500 - Art. 41)

Article 33 – Hours of Presentation (UCP 500 - Art. 45)

Article 34 – Disclaimer on Effectiveness of Documents

(UCP 500 - Art. 15)
Article 35 – Disclaimer on Transmission and Translation
(UCP 500 - Art. 16)
Article 36 – Force Majeure (UCP 500 - Art. 17)

55
Any Questions?

Our Technical Trade Specialists are happy to answer your technical LC questions. Please
mention that you attended our Introduction to UCP 600 for Importers Webinar!

Barbara Fernandez in Tampa, FL Victor Pena in Tampa, FL

Phone: 1-813-604-7088 Phone: 1-813-604-7042
E-Mail: barbara.e.fernandez@citigroup.com E-Mail: victor.a.pena@citigroup.com

Our Trade Bankers are available to provide additional information about our trade services,
our trade finance capabilities, and our global network. Please contact:

Phyllis Kai-Kee in New York, USA

Phone: 1-213-239-1749
E-Mail: phyllis.kaikee@citigroup.com

56
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