Moving Energy

Responsibly

Sanctions

Gunvor adheres strictly to all application international economic sanctions and regulations. Given the increasing importance of sanctions to international trade, we have expanded our function to specifically monitor sanctions evolution.

Throughout Gunvor’s counterparty due diligence process, sanctions checks are carried out both through third-party systems and Gunvor’s own internal processes. On a daily basis, the company vets its entire list of business counterparties and relevant associated individuals against international databases.

Gunvor’s Compliance Department, which includes personnel specifically dedicated to sanctions compliance, further regularly engages directly with governments that impose sanctions, including the United States, the United Kingdom, and the European Union, among others, to ensure there is clarity with respect to the latest developments and actions.

Gunvor has further invested millions of dollars in the latest IT systems to assist with counterparty and agent due diligence and tracking, ensuring all employees have access to system data. Counterparties and related parties in CMS are screened daily against external, third-party vendor systems, which monitor for such information as sanctions violations and PEP exposure, or other relevant events. The same applies for Gunvor’s vessel screening.

Counterparties and related parties in CMS are screened daily against external, third-party vendor systems

30,124

Business counterparties screened in 2022

15

Average number of vessels are screened daily

873

New counterparties onboarded in 2022

Counterparty Management System (CMS)

All Gunvor trading and operational systems are linked with the Counterparty Management System (CMS), centralizing all counterparty due diligence within a single, controlled environment. CMS ensures uniformity of processes and oversight. For example, all payments for the company are checked against CMS before any transfer of funds can be made.

Thanks to the centralized nature of the system, Compliance can react to any new information and, if required, deactivate a counterparty in all company systems within minutes. Vessels and owners are also screened daily through the CMS process.

Vessel Screening

Gunvor works with Pole Star for vessel screening. The PurpleTrac system is fully integrated within Gunvor’s CMS, leveraging its interface and escalation technology. On any single day, approximately 15 vessels are screened by Gunvor’s chartering teams. Compliance vessel screening is also integrated with the operational vessel vetting process, which ensures that comprehensive vessel screening must be completed prior to any vessel chartering.

Clearlake Shipping, Gunvor’s wholly owned chartering company, has developed its own vetting procedure to ensure that all tonnage controlled by the company, either through spot or time charter, has been screened and cleared to pass standards for vessel quality and international law. This procedure is conducted for every vessel and carried out jointly by Clearlake Shipping’s vetting and compliance teams.

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