# Compliance policy

> Yorkwell Petroleum checks every counterparty before a trade. This policy explains what we ask for, what we check and when we decline.

URL: https://yorkwellpetroleum.com/governance/compliance-policy/

## How a counterparty is checked

1. **Identity**: Company registration and authorized signatories
2. **Ownership**: Who owns and controls the company
3. **Screening**: Sanctions and other restricted-party lists
4. **Trade review**: Product, origin, route and payment
5. **Decision**: Approve, ask for more, or decline

Checks are repeated when a counterparty's details change.

## What we ask counterparties for

- Certificate of incorporation or registration
- Names of directors and authorized signatories
- Details of the owners and controllers
- A bank reference, or bank details in the company's own name
- For each trade, the product's origin and the shipping route

## Sanctions

As a U.S. company, Yorkwell Petroleum is subject to U.S. sanctions administered by the [Office of Foreign Assets Control (OFAC)](https://ofac.treasury.gov/). We screen counterparties, and the vessels and places involved in a trade, against the sanctions that apply.

## When we decline

- A party, owner, vessel or place in the trade is subject to sanctions that apply
- Ownership cannot be established
- Documents cannot be verified
- Payment is asked to go to an account not in the counterparty's own name

## Records

We keep the records of our checks for as long as the law requires.

## Questions

Questions about this policy can be sent to [info@yorkwellpetroleum.com](mailto:info@yorkwellpetroleum.com). See also our [code of conduct](https://yorkwellpetroleum.com/governance/code-of-conduct/).

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Yorkwell Petroleum · 440 Louisiana St, Ste 900, Houston, TX 77002 · info@yorkwellpetroleum.com · +1 (713) 239-3396