Paymaster Services & Blind Transactions

Funds held in trust. Identities kept confidential.

Stewart Law International acts as paymaster and conducts blind cross‑border commodity transactions.

Request a paymaster engagementRequest a blind transaction
NEW YORK LONDON ZURICH DUBAI SINGAPORE TRANSACTION CORRIDORS
Services

Two services for cross-border commodity transactions.

The firm acts as paymaster, conducts blind transactions, or does both on the same transaction.

Service 01

Paymaster Services

Custody and disbursement of transaction funds by counsel

In high-value and cross-border transactions, the hardest question is often who holds the money. Buyers will not release funds before performance, sellers will not perform without assurance of payment, and intermediaries need assurance that their commissions will be paid. A paymaster resolves this. Funds are held in an attorney trust account and disbursed to the seller and to each intermediary only when the agreed conditions are met.

Request a paymaster engagement
What it means for the parties
  • Independent custody. Funds are held in an attorney trust account, not by the buyer, the seller or an intermediary.
  • Conditional release. Funds are released only when the documents, certifications or confirmations specified in the signed paymaster agreement are received.
  • Protected commissions. Intermediary fees are paid directly from the trust account in accordance with the sale and purchase agreement (SPA) and the irrevocable master fee protection agreement (IMFPA).
  • Compliance review. Every party completes KYC and AML review, and disbursements are screened against applicable sanctions requirements.
  • Clear records. Every receipt and disbursement is confirmed in writing to the parties.
Who benefits
Buyers and sellers
Settlement against agreed conditions, with neither side holding the other's money.
Intermediaries
Commissions paid directly from the trust account and documented, in accordance with the IMFPA.
Also available

Entity formation and recipient accounts

For parties receiving proceeds, the firm forms entities and trusts, identifies beneficial owners as required by law, and assists with the opening of recipient accounts. Tax matters are addressed in coordination with qualified tax advisors.

Service 02

Blind Cross-Border Commodity Transactions

Counsel-managed, no-contact settlement for precious metals, petroleum products and other physical commodities

In a blind transaction, buyer and seller never deal with each other directly. Each contracts separately with the firm, and the firm conducts the transaction between them through closing. Neither party learns the other's identity.

Request a blind transaction
Why Stewart Law International
  • Attorney oversight. Every transaction is supervised by counsel bound by professional duties of confidentiality and care.
  • End-to-end confidentiality. Buyers and sellers remain anonymous to each other. Only the firm sees identities, product details and payment information.
  • Verified product and funds. Counsel confirms that the seller holds the commodity in proper custody and that the buyer controls the funds before the transaction proceeds.
  • Single point of settlement. Acting as paymaster, the firm manages the transaction from verification to disbursement, reducing fragmentation and settlement risk.
  • Compliance review. Every party completes KYC and AML review and sanctions screening before the transaction proceeds.
Suited to

Commodity brokers and financial institutions, investment managers, corporate treasury departments, and private buyers and sellers of physical commodities.

The firm also accepts litigation and advisory matters on a selective basis.

Process

How an engagement proceeds.

Paymaster Services

  1. Engagement requestThe client requests a paymaster engagement and is reviewed for acceptance.
  2. Paymaster agreementThe parties execute an agreement setting out the release conditions and disbursement schedule.
  3. Client documentationSubmitted through a secure portal: customer information sheet (CIS), IRS Form W‑9 or W‑8BEN for non-U.S. parties, and government-issued identification.
  4. Receipt of fundsFunds are deposited to the firm's trust account, and receipt is confirmed in writing to all parties.
  5. Disbursement consultationAn attorney confirms with the parties how, when and where funds are to be disbursed.
  6. Satisfaction of conditionsThe firm reviews and verifies the transaction documents, completes KYC and AML review, and confirms the paymaster instructions before release.
  7. DisbursementSeller proceeds and commissions are disbursed as scheduled, with each payment confirmed by wire reference.

Blind Transactions

  1. Initial consultationA call with the firm to review the transaction requirements: the commodity, quantity, specifications, delivery terms and timeline.
  2. EngagementBuyer and seller each enter a separate agreement with the firm setting out terms, quantity and price.
  3. KYC and AMLThe firm conducts know-your-customer, anti-money-laundering and sanctions review of each party.
  4. VerificationCounsel reviews custody evidence, inspection and assay reports, and the buyer's proof of funds, through the parties' banks and custodians.
  5. Transaction agreementsSale and purchase agreement (SPA), with an irrevocable master fee protection agreement (IMFPA) where intermediaries are involved.
  6. Payment securityThe buyer's funds are held in the firm's attorney trust account, or secured by a bank guarantee (BG) or documentary letter of credit (DLC).
  7. SettlementOnce both sides are verified, the firm releases funds against delivery, attorney to attorney and bank to bank. The parties never meet.
The Firm

J. Benton Stewart, II, Esq.

Founder

Mr. Stewart has practiced law for more than 25 years as a trial lawyer, prosecutor and judicial officer. He served as a magistrate in Florida's Sixth and Thirteenth Judicial Circuits and as a prosecutor for the State of Kansas, and has appeared on matters in Abu Dhabi, Dubai, England, France, South Africa, the Bahamas and Bermuda.

Tribal law is a central part of his practice, including work with tribal nations and Indigenous-owned enterprises.

He has taught advanced advocacy at Stetson University College of Law and professional responsibility at the University of Tampa, and has lectured on legal ethics for the American Bar Association, the Florida Bar and the National Institute for Trial Advocacy. He founded Stewart Law International to serve as counsel and paymaster on cross-border transactions.

Role
Founder
Admitted
Florida, 1997 (Florida Bar No. 126969) · District of Columbia, 2018 (D.C. Bar No. 1500585)
Judicial
Former Magistrate, Sixth & Thirteenth Judicial Circuits, Florida
Teaching
Former Adjunct Professor, Stetson University College of Law
Writing
Ethics in International Law · Safe Harbor Provisions for U.S. Attorneys Working Internationally · Mandatory International Arbitration and Ethics
Memberships
American Bar Association · Federal Bar Association · Hillsborough County Bar Association · National Tribal Counsel · Master, American Inns of Court
Office
Washington, D.C.
Contact

Contact the firm.

The firm will be in touch within one to two business days.

Washington, D.C. Office
1717 N Street NW
Washington, DC 20036
Florida Mailing Address
11705 Boyette Road, Suite 205
Riverview, FL 33569
Telephone
(202) 888-6007

Please do not submit confidential information through this form. Submitting it does not create an attorney-client relationship.

Paymaster Services

Request a paymaster engagement.

Provide your details and a brief description of the transaction. You may also request paymaster services for the other parties to the transaction. The firm will contact each party within one to two business days.

Transaction

Use the same name each party is given, so all requests for this transaction are grouped together.

Your details

The first and last name of the person who referred you.

Add or Invite Other Parties (optional)

Add each party who also requires paymaster services. The firm will contact them only regarding this engagement.

Please do not submit confidential transaction documents through this form. Submitting it does not create an attorney-client relationship; engagements are accepted after review.
Blind Transactions

Request a blind transaction.

Tell us briefly what you would like help with. The firm will be in touch within one to two business days.

Your details
The transaction

Please do not submit confidential documents through this form. Submitting it does not create an attorney-client relationship.