Anti-money laundering and counter-terrorist financing policy

1. Purpose

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy (the Policy) sets out the principles, rules and procedures adopted by Gulf Titans International Offshore Crude Oil Trading L.L.C (Gulf Titans International or the Company) to prevent, detect and report money laundering, terrorist financing, proliferation financing and related financial crimes.

The Policy aims to ensure compliance with the applicable laws and regulations of the United Arab Emirates, including but not limited to:

• Federal Decree-Law No. (10) of 2025 regarding Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, which repealed and replaced Federal Decree-Law No. (20) of 2018
• Cabinet Decision No. (10) of 2019 and its amendments, to the extent it remains in force pending new executive regulations
• Cabinet Decision No. (74) of 2020 on the Terrorism Lists Regulation and the implementation of UN Security Council resolutions (Targeted Financial Sanctions)
• Relevant regulations, guidelines and circulars issued by UAE authorities, including the Ministry of Economy, the UAE Financial Intelligence Unit (FIU) and the Executive Office for Control and Non-Proliferation (EOCN)

2. Scope

This Policy applies to:

• The Company, its management, directors, officers and employees
• All customers, counterparties, agents, intermediaries and business partners
• All business activities, transactions and services of the Company, including trades in crude oil and refined petroleum products concluded directly or through brokers and intermediaries

3. Definitions

• Money Laundering (ML): any act intended to conceal or disguise the illicit origin of proceeds derived from criminal activity.
• Terrorist Financing (TF): the provision, collection or movement of funds intended to support terrorist acts or organisations.
• Proliferation Financing (PF): the provision of funds or services used for the manufacture, acquisition or transfer of weapons of mass destruction.
• Beneficial Owner: the natural person or persons who ultimately own or control a customer or counterparty, directly or indirectly.
• Customer Due Diligence (CDD): measures taken to identify and verify customers and assess ML and TF risks.
• Enhanced Due Diligence (EDD): additional checks applied to higher-risk customers or transactions.
• Targeted Financial Sanctions (TFS): asset freezing and prohibition measures applied to persons and entities designated on UAE and UN sanctions lists.
• Suspicious Transaction: any transaction that raises suspicion of ML, TF, PF or other illegal activity.

4. Governance and responsibility

Senior management is responsible for:

• Approving and overseeing the implementation of this Policy
• Ensuring adequate resources are allocated to AML and CTF compliance
• Promoting a culture of compliance and ethical conduct

Compliance Officer and MLRO

The Company appoints a Compliance Officer or Money Laundering Reporting Officer (MLRO) responsible for:

• Implementing and monitoring AML and CTF controls
• Reviewing suspicious activities and transactions
• Submitting Suspicious Transaction Reports (STRs) to the UAE FIU through the goAML platform, where required
• Maintaining sanctions screening and TFS procedures
• Acting as the main point of contact with regulators and counterparties on compliance matters

5. Risk-based approach

The Company adopts a risk-based approach to AML and CTF, assessing risks related to:

• Customer type and ownership structure
• Country or geographic exposure
• Products, services and delivery channels
• Transaction size, volume and complexity
• Commodity and trade flow risk, including product origin, loading and discharge ports, vessels and shipping routes

Proportionate controls

Appropriate controls are applied according to the assessed level of risk.

6. Customer due diligence

Before entering into a business relationship, and before issuing or accepting any LOI, ICPO, FCO or sale and purchase agreement, the Company:

• Identifies and verifies customers using reliable, independent documents
• Identifies the beneficial owners of corporate customers
• Understands the nature and purpose of the business relationship

Standard due diligence information

This may include:

• Legal name, address and contact details
• Trade licence and incorporation documents
• Identification documents of authorised signatories
• Ownership and control structure
• Bank details, confirmed bank to bank where appropriate

Enhanced due diligence

Enhanced due diligence is applied where higher money laundering or terrorist financing risks are identified, including:

• Politically Exposed Persons (PEPs)
• High-risk jurisdictions
• Unusual or complex transactions
• Counterparties unable to demonstrate title to, or availability of, the product offered
• Transactions routed through multiple brokers or intermediaries

7. Ongoing monitoring

The Company:

• Monitors transactions to ensure they are consistent with the customer's profile
• Reviews and updates customer information periodically
• Investigates unusual or suspicious activities promptly

8. Sanctions and watchlist screening

The Company screens customers, counterparties, beneficial owners, banks and vessels against:

• The UAE Local Terrorist List
• The United Nations Security Council Consolidated List
• Other applicable international sanctions lists, including those of the United States (OFAC), the European Union and the United Kingdom, where relevant to the transaction, currency or counterparties involved

Confirmed matches

Where a match with a designated person or entity is confirmed, the Company freezes the relevant funds or assets without delay, does not make funds or services available, and reports to the competent UAE authorities as required. Business relationships are not established or continued where sanctions restrictions apply.

9. Oil and petroleum trade controls

Given the nature of its business, the Company applies the following additional controls:

• Verify the origin of crude oil and petroleum products through certificates of origin, loading documents and independent inspection reports; the Company does not deal in product originating from sanctioned jurisdictions or in breach of applicable restrictions
• Screen vessels by IMO number, flag, registered owner and manager; treat AIS gaps, unexplained ship to ship transfers and frequent re-flagging or renaming as red flags
• Verify the seller's title to and availability of the product through independent inspection and terminal confirmation before any payment obligation arises
• Receive and make payments only through the Company's bank accounts, to or from the contractual counterparty; cash transactions are not permitted

Red flags

Red flags that require escalation to the MLRO include prices materially below market, requests for upfront fees before verification, payments to or from unrelated third parties, broker chains with no clear role, reluctance to provide KYC or bank to bank verification, and inconsistencies in shipping or trade documents.

10. Reporting of suspicious transactions

• Employees must promptly report any suspicious activity to the Compliance Officer or MLRO
• The MLRO evaluates the report and, where required, submits an STR to the UAE FIU without delay
• Tipping off customers or third parties is strictly prohibited
• Employees who report in good faith are protected from retaliation

11. Record keeping

The Company maintains records of:

• Customer identification and verification documents
• Transaction and shipping records
• Sanctions screening results, AML and CTF reports and internal investigations

Retention period

Records are retained for a minimum of five years from the end of the business relationship or the date of the transaction, or longer where required by applicable law.

12. Training and awareness

• Employees receive AML and CTF training upon hiring and periodically thereafter
• Training covers legal obligations, red flags, sanctions and internal reporting procedures

13. Confidentiality and data protection

All AML-related information is handled confidentially and used solely for compliance with legal and regulatory obligations.

14. Breaches and disciplinary action

Any breach of this Policy may result in disciplinary action, including termination of employment and potential legal consequences.

15. Policy review and updates

This Policy is reviewed at least annually and updated as necessary to reflect changes in laws, regulations or business operations.

Approval

This Policy is approved by the management of Gulf Titans International Offshore Crude Oil Trading L.L.C and is effective from 30 September 2026.