[{"data":1,"prerenderedAt":166},["ShallowReactive",2],{"legal-compliance":3},{"id":4,"title":5,"body":6,"description":157,"draft":158,"extension":159,"lastUpdated":160,"meta":161,"navigation":158,"path":162,"seo":163,"stem":164,"__hash__":165},"legal\u002Fen\u002Flegal\u002Fcompliance.md","Compliance — sanctions, KYC, AML",{"type":7,"value":8,"toc":147},"minimark",[9,20,25,28,59,63,66,80,83,87,90,104,108,111,122,125,129,140,144],[10,11,12],"blockquote",{},[13,14,15,19],"p",{},[16,17,18],"strong",{},"Draft."," This text is a working draft pending counsel review. The petrochemical business unit's exposure to sanctions-relevant origins requires explicit legal sign-off before publication.",[21,22,24],"h2",{"id":23},"_1-statement","1. Statement",[13,26,27],{},"SATco Group operates within the international sanctions and export-control regimes that apply to its activities. We monitor and apply the following sanction lists:",[29,30,31,38,44,50,56],"ul",{},[32,33,34,37],"li",{},[16,35,36],{},"United Nations"," Security Council Consolidated List",[32,39,40,43],{},[16,41,42],{},"European Union"," Restrictive Measures",[32,45,46,49],{},[16,47,48],{},"United States"," OFAC Specially Designated Nationals (SDN)",[32,51,52,55],{},[16,53,54],{},"United Kingdom"," OFSI Consolidated List",[32,57,58],{},"Applicable national sanction lists in the jurisdictions of our operating entities (China, Hong Kong SAR, Bahrain, Portugal)",[21,60,62],{"id":61},"_2-counterparty-due-diligence-kyc","2. Counterparty due diligence (KYC)",[13,64,65],{},"Every counterparty — buyer, seller, intermediary, agent — is subject to know-your-counterparty (KYC) due diligence before any transaction is concluded. KYC includes:",[29,67,68,71,74,77],{},[32,69,70],{},"Identity verification (corporate registry, beneficial-ownership lookup, sanctions-list screening)",[32,72,73],{},"Industry and activity check",[32,75,76],{},"Country and end-use review",[32,78,79],{},"Re-screening at defined intervals and on each new transaction",[13,81,82],{},"Counterparties unable or unwilling to satisfy our KYC requirements are not transacted with.",[21,84,86],{"id":85},"_3-anti-money-laundering-aml","3. Anti-money-laundering (AML)",[13,88,89],{},"Our AML controls follow the FATF recommendations and are applied across all SATco Group entities. Controls include:",[29,91,92,95,98,101],{},[32,93,94],{},"Documented source-of-funds verification on transactions above defined thresholds",[32,96,97],{},"Suspicious-transaction reporting via the channels mandated in each operating jurisdiction",[32,99,100],{},"Annual AML training for staff with counterparty-facing roles",[32,102,103],{},"Periodic external audit of AML controls",[21,105,107],{"id":106},"_4-petrochemical-specific-posture","4. Petrochemical-specific posture",[13,109,110],{},"The petrochemical business unit holds direct supply relationships with refineries in multiple jurisdictions, including some that are subject to ongoing international restrictions. For each transaction we:",[29,112,113,116,119],{},[32,114,115],{},"Verify the cargo's origin against current sanctions",[32,117,118],{},"Verify the destination port and ultimate end-use against current restrictions",[32,120,121],{},"Confirm payment-channel compliance with the relevant national bank's correspondence requirements",[13,123,124],{},"Where any element of a transaction would breach an applicable sanction, the transaction is not proceeded with — irrespective of commercial impact.",[21,126,128],{"id":127},"_5-reporting-concerns","5. Reporting concerns",[13,130,131,132,139],{},"If you believe a SATco Group transaction may involve a breach of applicable sanctions, KYC, or AML obligations, please contact our compliance team at ",[16,133,134],{},[135,136,138],"a",{"href":137},"mailto:arturbastos@satcogrp.com","arturbastos@satcogrp.com",". We treat all reports confidentially and investigate.",[21,141,143],{"id":142},"_6-no-legal-advice","6. No legal advice",[13,145,146],{},"This statement is informational. It does not constitute legal advice and does not modify any contractual obligation under a separate agreement.",{"title":148,"searchDepth":149,"depth":149,"links":150},"",2,[151,152,153,154,155,156],{"id":23,"depth":149,"text":24},{"id":61,"depth":149,"text":62},{"id":85,"depth":149,"text":86},{"id":106,"depth":149,"text":107},{"id":127,"depth":149,"text":128},{"id":142,"depth":149,"text":143},"SATco Group's posture on international sanctions, know-your-counterparty due diligence, and anti-money-laundering controls — particularly relevant to the petrochemical business unit.",true,"md","2026-05-03",{},"\u002Fen\u002Flegal\u002Fcompliance",{"title":5,"description":157},"en\u002Flegal\u002Fcompliance","YIoVBoWY-nLagClc4Oc1OpOLx5qCX0u6sd1PlMBjwrw",1778405837592]