Trade and Refining of Petroleum Products

Compliance with Sanctions Laws. The Company or person , nor any of its subsidiaries or, to the knowledge of the Company or person , any director, officer, agent, employee or affiliate of the Company or any of its subsidiaries is currently subject to any sanctions administered or enforced by the U.S. government, (including, without limitation, the Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”) or the U.S. Department of State and including, without limitation, the designation as a “specially designated national” or “blocked person”), the United Nations Security Council (“UNSC”), the European Union, or other relevant sanctions authority (collectively, “Sanctions”), nor is the Client or any of its subsidiaries located, organised or resident in a country or territory that is the subject or target of Sanctions, currently Crimea, Cuba, Iran, North Korea, Syria, Belarus, Russian Federation (each, a “Sanctioned Country”); and the Company will not directly or indirectly use the proceeds of the offering of the Securities hereunder, or lend, contribute or otherwise make available such proceeds to any subsidiary, joint venture partner or other person or  group or company, group for the purpose of financing the activities of any person currently subject to any Sanctions, or in any other manner that will result in a violation by any person (including any person participating in the transaction, whether as underwriter, advisor, investor or otherwise) of Sanctions. The Company and its subsidiaries have not knowingly engaged in, are not now knowingly engaged in any dealings or transactions with any person that at the time of the dealing or transaction is or was the subject or the target of Sanctions or with any Sanctioned.

Compliance with Money Laundering Laws. The operations of the Client and its subsidiaries are and have been conducted at all times in compliance in all material respects with applicable financial record-keeping and reporting requirements, including those of the Currency and Foreign Transactions Reporting Act of 1970, as amended, the money laundering statutes of all jurisdictions where the Client or any of its subsidiaries conducts business, the rules and regulations thereunder and any related or similar rules, regulations or guidelines, issued, administered or enforced by any governmental agency (collectively, the “Money Laundering Laws”) and no action, suit or proceeding by or before any court or governmental agency, authority or body or any arbitrator involving the Client or any of its subsidiaries with respect to the Money Laundering Laws is pending or, to the best knowledge of the Company, threatened.

The Parties warrants that neither it nor any of its subsidiaries or affiliates or, to the Clients knowledge, any director, officer, or employee of the Client or any of its subsidiaries or affiliates is:

1. an individual or legal company (“Person”) currently on a sanctions list, including, but not limited to, the US Consolidated Screening List (“CSL”) and the EU Consolidated Sanctions List.
2. is in a country or territory that is a target of sanctions or whose government is currently the target of sanctions.
3. is a Person who is directly or indirectly owned or controlled by any Person currently on a sanction list or is directly or indirectly owned or controlled by any Person who is in a country or territory that is a target of, or whose government is currently a target of, sanctions.
4. is a Person subject to ongoing investigations into possible sanctions; and
5. the Client will not directly or indirectly supply or otherwise make available any export-controlled items, whether.

(i) to a subsidiary or affiliate, joint venture partner or other Person or country or territory whose government is the target of sanctions, or.

(ii) in any other way that would result in a violation of sanction.

Specially Designated Nationals

All individuals and companies owned or controlled by, or acting for or on behalf will be screened for exposure to Sanctions. Any financial transaction involving a US COMPANY or person of any type is subject to OFAC sanction regulation. This can extend to include a non-US company that acts as a middleman between a company and a potentially SDN-listed individual.

SDN-Controlled Entities and Significant SDN Ownership

The 50 percent rule applies whenever a sanctioned or blacklisted Company or person owns more than 50% of another Company. In this case, the latter receives the same sanctions or limitations, and it can’t do business in the affected territory – neither can entities in that territory do business with the sanctioned company.

US Patriot Act and Foreign Corruption Act

All individuals and companies owned or controlled by, or acting for or on behalf will be screened for compliance with US Patriot Act and Foreign Corruption Act.

USA National Security Study Memorandum-1 (NSSM-1)

All individuals and companies owned or controlled by, or acting for or on behalf will be screened for compliance with USA National Security Study Memorandum-1 (NSSM-1)