Sanctions Policy
How the Registry screens applicants, holders, directors and beneficial owners against international sanctions regimes, and what happens when a match is found.
1. Commitment
The Registry will not issue or maintain a code for any person with whom dealings are prohibited under the sanctions laws that apply to Eurabelt Fuels Ltd and its group entities. It will not allow the Registry to be used to evade sanctions.
2. Regimes observed
At a minimum, the Registry screens against:
- the UK Sanctions List, with guidance from OFSI;
- the UN Security Council Consolidated List;
- the Consolidated Canadian Autonomous Sanctions List and listings under Canada's Criminal Code;
- the South African Targeted Financial Sanctions list maintained by the Financial Intelligence Centre;
- the Trinidad and Tobago consolidated list of court orders under the Anti-Terrorism Act;
- EU restrictive measures (EU Sanctions Map) and US OFAC lists (Sanctions List Search). These are applied as a matter of risk policy, because fuel-industry counterparties are commonly subject to them.
Sector-specific measures affecting petroleum, including oil price caps, import bans, restrictions on maritime services and vessel designations, are considered as part of verification where relevant to the applicant's stated role.
3. Who is screened
- The applicant entity and its trading names
- Directors, authorised signatories and the authorised contact
- Beneficial owners holding 25% or more, or exercising control by other means
- Parent entities, where known
4. When screening happens
- Before issuance, when the screening reference is recorded against the application
- At least monthly for every active holder
- When a relevant list changes materially
- When a holder reports a change of ownership or control
5. Outcomes
| Result | Action |
|---|---|
| Clear | Issuance may proceed. |
| Clear with notes | Issuance may proceed; notes are recorded and reviewed at the next monitoring cycle. |
| Potential match | Issuance is halted, or an active code is suspended, until the match is resolved. |
| Confirmed match | The application is declined, or the code is revoked. Assets are frozen and reports are made to the competent authority where the law requires. |
The Registry does not tell the subject that a report has been made where doing so is prohibited by law (tipping off).
6. Enhanced-review jurisdictions
Applications connected to jurisdictions subject to comprehensive or broad sectoral sanctions are flagged automatically for enhanced review. A flag is not a refusal. It triggers additional checks on ownership, control, the origin and destination of product, and the applicability of any licence or exemption.
7. Licences
Where an applicant relies on a sanctions licence or general licence, a copy must be provided. The code will reflect only activity within the licence's scope.
8. Reporting concerns
Report sanctions concerns to compliance@eurabeltfuels.com, or anonymously under the Speak-Up Policy.