Clear standards for every counterparty and movement

Sanctions

Poseidon does not accept customers, introducers, suppliers or other counterparties who are located in, incorporated in, or controlled from a jurisdiction subject to comprehensive sanctions, and does not knowingly participate in a transaction involving a sanctioned party, vessel, cargo or destination.

We screen against the sanctions requirements and published lists relevant to the company and the transaction. In practice that means the United Nations Security Council consolidated list, the European Union consolidated list, the UK OFSI consolidated list, the US OFAC list of Specially Designated Nationals and the measures implemented by Singapore.

This applies to the counterparty and to the transaction. A shipment can be refused because of the vessel, the flag, the ownership behind it, the origin of the cargo or the discharge destination, even where the customer is unobjectionable.

Jurisdictions we do not work with

As an internal risk policy, Poseidon declines enquiries from counterparties incorporated in Cuba, Iran, North Korea, Syria, Russia, Belarus, Myanmar and Afghanistan, and from Crimea and the non-government-controlled areas of Donetsk, Luhansk, Kherson and Zaporizhzhia. This policy is broader than a statement of which countries are subject to comprehensive sanctions under any one legal regime. The enquiry form applies the policy before any commercial discussion takes place.

A further group of jurisdictions is accepted only into enhanced due diligence, never into automatic acceptance. In practice that means more documentation, longer lead times and a decision made by a person rather than a form. Country screening is only the first step: acceptance remains subject to the parties, vessel, cargo, route, banks and complete transaction structure.

What we check on every counterparty

• Legal name, registration number and country of incorporation
• Ownership and control, including ultimate beneficial ownership where it is not obvious
• Sanctions list screening of the company, its owners and its directors
• Adverse media where the profile or the transaction warrants it
• The vessel, its flag, its ownership and its recent trading pattern, on a chartered fixture
• The origin of the cargo and the discharge destination

Vessel screening before a fixture

Vessel screening begins with identity. We check the IMO number rather than relying on a ship name that can change, then review the current name and flag, registered ownership and available control information. Those details are tested against the sanctions lists named above and against the vessel's recent trading pattern where it is relevant to the proposed cargo and route.

The review is separate from technical and commercial acceptance. A vessel can pass a sanctions screen and still be unsuitable because of terminal approval, class, insurance, age, flag, recent cargoes or charterer vetting. In tanker business, SIRE or CDI records, last cargoes and terminal acceptance remain part of the fixture process rather than proof that sanctions screening has been completed.

Screening is a point-in-time decision on the parties and vessel then proposed. A vessel substitution or a material change in ownership, control, flag, route or counterparty requires the replacement facts to be checked before Poseidon proceeds. This is not a promise of continuous automated monitoring after the fixture.

What we will ask you for

For most transactions, a certificate of incorporation or an equivalent registry extract, a list of directors and beneficial owners, and identification for the person we deal with. For larger or more complex transactions we may ask for evidence of the source of funds and for details of the underlying trade.

We ask for these once and we ask early. A counterparty who will not provide them is not a counterparty we can work with, regardless of the cargo.

Reporting and refusal

We make any report required by applicable law and do not disclose it where the law prohibits disclosure. We may decline or discontinue a transaction at any point without giving a reason, and we will not proceed with a transaction we believe to be designed to evade sanctions.

Introducers and anti-corruption

Referral fees are available only under a written agreement with an authorised introducer. Poseidon does not pay an undisclosed fee to an employee, procurement representative or agent of a referred counterparty, a public official, or any person whose receipt of the fee would breach a duty, policy or law. Employment and agency relationships must be disclosed, and any required employer or principal approval must be obtained before the introduction.

Payments

Clients contract with and pay appointed carriers and service providers directly. Poseidon does not receive or transmit client freight payments and does not hold customer balances or assets. Poseidon receives its commission from the appointed provider. The commercial and payment structure explains the model in full.