Sanctions Compliance and Due Diligence Framework

Sanctions Compliance

The Company provides shipping services for petroleum and oil products through its tanker fleet and is fully committed to maintaining the highest standards of regulatory compliance. To safeguard against exposure to sanctioned countries, entities, persons, vessels, or prohibited trade activities—including but not limited to Iran, Russia, Venezuela, or any other sanctioned origin—the Company has established a robust sanctions compliance and due diligence framework.

To ensure that all cargoes carried onboard are lawful and compliant with international sanctions regimes, the following checks and controls are implemented prior to fixture acceptance and throughout voyage monitoring:

1. Vessel and Trade Compliance Screening

The Company utilizes subscription based compliance screening tools, including Marine Traffic compliance modules, to assess:

  • Regulatory risks relating to vessel identity, cargo, ownership, flag, and trading patterns
  • Operational risks such as AIS gaps, AIS spoofing or manipulation, dark STS operations, high risk STS transfers, and suspicious port calls
  • Management related risks including ISM manager, Classification Society, P&I Club, and PSC history
2. Independent Verification through Equasis

Independent verification is conducted via Equasis to review:

  • Vessel ownership and management history
  • Flag changes and re flagging patterns
  • Trading routes and operational history
  • Historical management and performance records
3. Sanctions Screening

All vessels, owners, managers, charterers, and relevant counterparties are screened against applicable sanctions lists, including:

  • United Nations (UN)
  • United States (OFAC)
  • European Union (EU)
  • United Kingdom (UK)

Screening is performed using official OFAC search tools and recognized industry compliance platforms as part of the Company’s due diligence procedures.

4. Cargo and Voyage Due Diligence

The Company reviews cargo origin, load and discharge ports, STS history, voyage patterns, and counterparties prior to accepting employment. Any voyage or transaction presenting elevated sanctions exposure is subject to enhanced due diligence and may be declined.

5. AIS and STS Monitoring

Continuous monitoring is conducted to detect:

  • Intentional AIS disablement or spoofing
  • Unexplained AIS gaps
  • Dark activities
  • High risk ship to ship operations that may indicate sanctions evasion practices
6. P&I Club Guidance and Support

The Company consults its P&I Club for:

  • Enhanced sanctions due diligence support
  • Compliance advisories, circulars, and regulatory updates
  • Assessment of high risk trades, sanctioned jurisdictions, suspicious vessel activity, and cargo exposure

In cases involving elevated sanctions exposure or complex trade structures, additional scrutiny and guidance may be sought from the insurance provider before proceeding with any transaction or voyage.

Through these layered controls, the Company maintains a strong, proactive sanctions compliance environment and ensures that all operations remain fully aligned with international regulatory requirements.

Due Diligence Framework

The Company maintains a comprehensive sanctions policy and compliance framework, fully aligned with international sanctions regimes issued by the United Nations (UN), the United States (OFAC), the European Union (EU), and the United Kingdom (UK).

We follow a risk based approach designed to identify, assess, and mitigate sanctions exposure across all commercial and operational activities. Our framework incorporates the following core controls:

  • Formal Sanctions Policy A documented policy outlining prohibited activities, high risk jurisdictions, and mandatory compliance requirements in accordance with UN, US, EU, and UK regulations.
  • Counterparty Screening All customers, suppliers, vessels, and related third parties are screened against global sanctions lists (UN, OFAC, EU, UK) prior to engagement and on a continuous basis. Screening is conducted through official sanctions portals and recognized industry compliance platforms.
  • Cargo Origin Verification Robust due diligence procedures ensure that all oil and gas cargoes handled are not of Iranian or otherwise sanctioned origin. Cargo documentation, voyage details, load/discharge ports, and trade routes are reviewed to confirm lawful origin and regulatory compliance.
  • Transaction Monitoring All commercial and financial transactions are assessed to ensure there is no direct or indirect involvement with sanctioned countries, entities, individuals, or prohibited trade activities.
  • AIS and STS Monitoring Continuous monitoring is conducted to detect AIS gaps, AIS spoofing or manipulation, suspicious trading patterns, and high risk ship to ship operations that may indicate sanctions evasion activity.
  • Internal Controls and Escalation Any sanctions related red flags are escalated to management and the compliance function for review. The Company reserves the right to decline or terminate any fixture or transaction presenting sanctions concerns.
  • Employee Awareness and Training Personnel involved in commercial, operational, and financial functions receive ongoing training to identify and report sanctions related risks.

    • Through these measures, the Company ensures full adherence to international sanctions requirements and maintains a strong, proactive compliance environment.