Sanctions & Export Controls Compliance Policy

Tide Table Logistics Ltd

Purpose

The purpose of this Sanctions & Export Controls Compliance Policy is to safeguard Tide Table Logistics Ltd against the legal, financial, and reputational risks associated with violations of international sanctions and export control regulations. This policy affirms the company’s commitment to conducting all global logistics, trading, and maritime operations in accordance with applicable national and international laws, including but not limited to the following key regulatory frameworks:

Applicable Legal and Regulatory Frameworks

Tide Table Logistics Ltd rigorously adheres to the following key legal instruments and regulatory frameworks to ensure comprehensive compliance with sanctions and export control obligations:
● United Kingdom Sanctions and Anti-Money Laundering Act 2018 (SAMLA):
This legislation empowers the UK government to independently impose, amend, and enforce sanctions. It covers a wide range of restrictive measures, including financial sanctions, trade embargoes, immigration controls, and transport prohibitions. The Act serves as the primary legal basis for the UK’s sanctions regime, administered by the Office of Financial Sanctions Implementation (OFSI).

● U.S. Office of Foreign Assets Control (OFAC) Regulations:
OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security objectives. These regulations apply extraterritorially in many cases and prohibit any dealings with individuals or entities listed as Specially Designated Nationals (SDNs), as well as embargoed countries and sectors. Compliance with OFAC rules is critical to avoid severe legal and financial penalties.

● European Union and United Nations Sanctions Regimes:
The European Union implements sanctions through Council Regulations which either align with or expand upon United Nations Security Council Resolutions. These regimes impose various restrictive measures, including asset freezes, travel bans, and trade prohibitions targeting designated persons, entities, and countries. UN Security Council Resolutions are binding on all member states, making adherence mandatory.

● Ghanaian Export Control and Trade Regulations:
Overseen by the Ministry of Trade and Industry and supported by the Financial Intelligence Centre (FIC) and other national regulators, these laws govern export licensing, embargo enforcement, and trade compliance. Special emphasis is placed on strategic sectors such as minerals and petroleum, where national security concerns are paramount. These regulations are essential for maintaining legal trade flows and preventing violations within Ghanaian jurisdiction.

Together, these frameworks establish the foundation of Tide Table Logistics Ltd’s sanctions compliance program, guiding its sanctions screening processes, transaction monitoring, and escalation protocols. Strict adherence ensures the company effectively prevents engagement with restricted parties and unlawful trade activities, thereby protecting its legal standing and corporate integrity.

Policy Objectives

The Sanctions & Export Controls Compliance Policy is designed to uphold Tide Table Logistics Ltd’s commitment to the highest standards of regulatory compliance and ethical business conduct across all international operations. The policy specifically aims to:
● Prevent Prohibited Engagements:
Ensure that the company refrains from any direct or indirect dealings with sanctioned individuals, entities, vessels, or countries as designated by authoritative bodies including the United Kingdom, United States, European Union, United Nations, and Ghanaian regulatory authorities.

● Prohibit Unauthorized Trade:
Strictly forbid the import, export, or transit of embargoed commodities or services unless such activities are expressly authorized by the relevant regulatory agencies through appropriate licenses, permits, or exemptions.

● Implement Robust Internal Controls:
Develop, maintain, and continuously enhance internal mechanisms that facilitate the timely identification, assessment, and escalation of transactions or relationships that may pose sanctions or export control risks.

● Mitigate Inadvertent Non-Compliance:
Reduce the likelihood of unintentional breaches by providing comprehensive, role-specific training to employees, deploying automated sanctions screening systems, enforcing real-time due diligence processes, and maintaining thorough and accurate documentation of all relevant transactions and decisions.

● Demonstrate Ethical and Transparent Business Practices:
Affirm the company’s dedication to conducting all business in a transparent, responsible, and ethical manner consistent with applicable international laws and recognized industry standards and best practices.

By integrating these objectives into the company’s operational framework, Tide Table Logistics Ltd enhances its capacity to detect and respond to compliance risks proactively, adapt to dynamic regulatory requirements, and sustain trustworthy, lawful partnerships within the global trade ecosystem.

Scope

This policy applies comprehensively to all business units, personnel, and operational activities conducted by Tide Table Logistics Ltd throughout its global operations. It governs both direct and indirect engagements that may present sanctions or export control risks. Specifically, the policy covers the following areas:
● Commodity Procurement and Sales:
Includes all transactions involving petroleum products, precious minerals, and other goods subject to international trade regulations.

● Vessel Charters and Marine Logistics Services:
Encompasses activities such as ship registration, routing, screening of beneficial ownership, and the negotiation and execution of charter-party agreements.

● Client Onboarding and Transactional Communications:
Covers all communications—whether via email, proposals, contracts, or negotiations—with counterparties operating across various jurisdictions.

● Cargo Documentation and Shipping Instructions:
Involves preparation, verification, and approval of critical shipping documents, including bills of lading, cargo manifests, export permits, and customs declarations.

● Financial Transfers and Trade-Related Payments:
Pertains to all financial transactions linked to cross-border trade, including wire transfers, letters of credit, and correspondent banking activities.

This policy is enforceable across all jurisdictions where Tide Table Logistics Ltd operates, including the United Kingdom, Ghana, and international or offshore markets. It is mandatory for all employees, contractors, agents, and third parties acting on behalf of the company to comply fully with these standards. Strict adherence ensures that no element of Tide Table’s operations directly or indirectly contravenes applicable sanctions laws or export control regulations.

Legal & Compliance Team Responsibilities

Sanctions & Watchlist Management

● The Legal & Compliance Team shall maintain continuous, real-time access to all applicable sanctions lists and watchlists to guarantee comprehensive and current compliance with regulatory obligations.
● These watchlists must encompass, at minimum, those issued by the following principal authorities:

  • U.S. Office of Foreign Assets Control (OFAC)

  • United Kingdom HM Treasury (HMT)

  • United Nations Security Council (UNSC)

  • European Union (EU)

  • Ghanaian Ministry of Trade, Industry, and relevant local regulatory bodies
    ● The team is responsible for actively monitoring updates, amendments, and changes to these sanctions regimes and ensuring that such modifications are promptly integrated into Tide Table Logistics Ltd’s automated screening and due diligence systems. This includes the addition or removal of restricted parties, alterations to embargoed destinations, and changes in applicable trade restrictions.
    ● Maintaining this up-to-date and dynamic access to sanctions data is essential for enabling effective due diligence, preventing any unauthorized engagement with sanctioned persons, entities, or activities, and minimizing potential legal, financial, and reputational risks to the company.

Regulatory Monitoring and Advisory

● The Legal & Compliance Team shall proactively monitor all relevant developments, amendments, and updates to international sanctions regimes, export control laws, and trade restrictions across all jurisdictions where Tide Table Logistics Ltd operates.
● This includes continuous surveillance of regulatory changes issued by key authorities such as OFAC, UK HM Treasury, the United Nations Security Council, the European Union, and Ghanaian regulatory bodies.
● Upon identification of any significant changes or emerging risks, the team will promptly issue clear, concise advisories and regulatory bulletins to all relevant business units.
● These communications will be supplemented by tailored training sessions and guidance materials, designed to enhance understanding and ensure practical compliance among employees at all operational levels.
● This proactive approach ensures that Tide Table Logistics Ltd remains fully compliant with evolving legal obligations and is well-equipped to mitigate emerging sanctions and export control risks.
● Legal Review and Risk Assessment:
Conduct thorough internal legal reviews and risk assessments of transactions or counterparties flagged as high-risk, complex, or ambiguous. Where necessary, coordinate with external legal counsel, compliance experts, or regulatory authorities to obtain specialized guidance or resolve uncertainties, ensuring that decisions are well-informed and compliant with all applicable laws and policies.

Sales, Logistics, and Documentation Teams

Mandatory Screening

● Conduct real-time sanctions and export control screening on all clients, suppliers, vessel owners, intermediaries, and any other third parties involved in Tide Table Logistics Ltd’s operations. Screening must occur at critical points, including during onboarding and prior to the finalization of every transaction, ensuring that no dealings are made with sanctioned or restricted parties.

Goods and Destination Classification

● All commodities managed by Tide Table Logistics Ltd—including but not limited to petroleum products, precious minerals, dual-use goods, and other internationally traded items—must be accurately classified in accordance with the relevant export control regulations applicable to each jurisdiction involved. This classification process ensures that goods are correctly identified under the appropriate tariff codes, export control lists, and licensing requirements.
● Additionally, all intended shipment destinations must be rigorously verified against current embargoes, trade restrictions, and special regulatory measures issued by competent authorities such as the UK HM Treasury, U.S. Department of Commerce, European Union, United Nations, and Ghanaian Ministry of Trade. Transactions involving embargoed or restricted destinations are strictly prohibited unless explicitly authorized through valid licenses or exemptions obtained from the appropriate regulatory bodies.
● This classification and destination verification process is vital to prevent inadvertent breaches of sanctions or export controls, ensuring compliance and mitigating legal and reputational risks for Tide Table Logistics Ltd.

Red Flag Escalation

● All employees must promptly escalate any suspicious findings or potential compliance concerns to the Legal & Compliance Team without delay. Early identification and escalation are vital to mitigate sanctions risks and ensure regulatory adherence. Key triggers requiring immediate escalation include, but are not limited to:

  • Confirmed or potential matches—whether full or partial—on any recognized sanctions or restricted party lists, signaling a possible prohibited relationship or transaction.

  • Use of complex or atypical shipping routes, particularly involving transshipment through jurisdictions identified as high-risk for sanctions circumvention or illicit trade activity.

  • Incomplete, ambiguous, or conflicting end-user or end-use declarations, which may indicate attempts to obscure the true nature, destination, or purpose of goods or services.

  • Unusual or non-standard payment arrangements, including those involving offshore bank accounts, third parties with no direct involvement in the transaction, or unexplained intermediaries that raise concerns of money laundering or sanctions evasion.
    ● Failure to promptly escalate such red flags may result in disciplinary action and exposes Tide Table Logistics Ltd to significant regulatory penalties and reputational harm. Cooperation between operational teams and Legal & Compliance is essential to uphold the company’s commitment to lawful and ethical international trade.

Accountability

● All employees bear individual responsibility for promptly identifying and escalating any sanctions or export control red flags encountered during their duties. Failure to recognize or escalate such concerns in a timely and accurate manner may lead to disciplinary measures, up to and including termination of employment. Such lapses not only compromise internal compliance but also expose Tide Table Logistics Ltd to significant legal, regulatory, and reputational risks.
● Sustained and proactive collaboration with the Legal & Compliance Team is essential to uphold the company’s commitment to lawful, ethical, and responsible conduct in all aspects of its international trade operations. Employees are encouraged to seek guidance whenever uncertain and to treat compliance as a shared priority integral to Tide Table Logistics Ltd’s ongoing success and integrity.

Procedures

1. Real-Time Screening

Scope of Screening:
● All counterparties involved in Tide Table Logistics Ltd’s operations—including clients, agents, beneficial owners, vessels, freight handlers, and intermediaries—must undergo rigorous sanctions and watchlist screening to prevent any engagement with restricted or sanctioned parties.

Applicable Sanctions Lists:
● Screening must be performed against the most current and authoritative lists, including but not limited to:

  • U.S. Office of Foreign Assets Control (OFAC) Sanctions Lists, including the Specially Designated Nationals (SDN) and Blocked Persons lists.

  • UK Sanctions List and the Consolidated List of Financial Sanctions Targets maintained by HM Treasury’s Office of Financial Sanctions Implementation (OFSI).

  • United Nations Security Council Sanctions Lists covering individuals, entities, and countries subject to international embargoes and asset freezes.

  • European Union Restrictive Measures, encompassing trade restrictions, asset freezes, and travel bans enacted by the EU Council.

  • Ghana’s Ministry of Trade and Industry sanctions lists, as well as watchlists issued by the Financial Intelligence Centre (FIC).

Timing and Frequency of Screening:
● Screening is mandatory at key transaction milestones:

  • Onboarding: Prior to establishing any contractual or commercial relationship with a new counterparty.

  • Contract Execution: Immediately before signing agreements or contracts to verify the counterparty’s status remains compliant.

  • Pre-Shipment or Payment: Prior to dispatch of any material shipment or processing of payments to ensure ongoing compliance, especially for repeat or long-term clients.

Methodology:
● Screening should leverage automated tools integrated with up-to-date sanctions databases where feasible, supplemented by manual review in cases of potential matches or ambiguous results.

Escalation Protocol:
● Any positive or potential match identified through screening must be immediately escalated to the Legal & Compliance Team for investigation. Transactions involving flagged parties must be suspended pending review and formal clearance.

2. Restricted Party List & Embargo Registry

● Internal Database Maintenance:
The Legal & Compliance Team shall maintain a comprehensive, regularly updated internal database that consolidates all restricted or high-risk parties, including individuals, entities, vessels, and intermediaries flagged by sanctions authorities. This registry will also track embargoed destinations, politically sensitive ports, and jurisdictions subject to trade restrictions.

● Embargoed Nations and Regions:
Tide Table Logistics Ltd strictly prohibits any business dealings—whether direct or indirect—with embargoed countries or regions, including but not limited to Iran, North Korea, Crimea, Syria, and others as defined by current sanctions frameworks. No transactions involving these jurisdictions may proceed without securing an explicit, valid license or exemption from the appropriate regulatory authority.

● Proactive Updates and Cross-Checks:
The database will be cross-checked against official sanctions lists such as those from OFAC, UK HM Treasury, the United Nations, and the European Union, ensuring that all flagged parties and embargoes are current and comprehensive.

● Access and Usage:
Relevant personnel across sales, logistics, legal, and compliance functions will have controlled access to this registry to ensure effective screening and prevent inadvertent violations. The system will integrate with transaction processing platforms where possible to enable automated alerts and blocks.

3. Training & Red Flag Identification

● Mandatory Training:
All employees in legal, compliance, sales, logistics, finance, and related departments must complete regular, mandatory training programs on sanctions compliance and export control regulations. This training will cover relevant laws, company policies, and practical procedures to ensure full understanding and adherence.

● Red Flag Awareness:
Training will emphasize the identification of common indicators of potential sanctions or export control risks, including but not limited to:

  • Unusual or indirect routing of shipments or payments through sanctioned or high-risk jurisdictions.

  • Transactions involving shell companies, nominee entities, or third-party intermediaries lacking transparent ownership or control.

  • Customer documentation that is vague, incomplete, inconsistent, or suspiciously altered.

  • Last-minute or unexplained changes to shipping instructions, destinations, or vessel details.

  • Attempts to conceal cargo contents, vessel identity, or beneficial ownership to evade detection.

● Ongoing Updates:
Training content will be updated periodically to reflect evolving sanctions regimes, emerging typologies, and lessons learned from internal audits or external enforcement actions.

4. Transaction Freezing & Escalation

Immediate Freeze
● Upon identification of a confirmed or suspected match to any sanctions list, involvement of restricted parties, or engagement in prohibited activities, the transaction shall be immediately suspended and frozen.
● This freeze applies to all stages of the transaction, including financial transfers, shipment release, contractual obligations, and any operational execution.
● The primary objective is to prevent any further processing, movement of goods, or disbursement of funds that could contravene applicable sanctions or export control regulations.
● The transaction must remain frozen pending a full investigation and receipt of written clearance from the Compliance Officer or the relevant regulatory authorities.

Reporting and Investigation
● Once a transaction is frozen due to a confirmed or suspected sanctions or export control risk, it must be promptly reported to the designated Compliance Officer.
● The Compliance Officer shall undertake a comprehensive review and enhanced due diligence process to evaluate the nature, legitimacy, and potential risk associated with the transaction.
● This investigation will include consultation with internal legal advisors to interpret applicable laws and regulations, as well as engagement with external legal counsel or regulatory authorities when necessary to resolve complex or ambiguous compliance issues.
● Based on the findings, the Compliance Officer is responsible for preparing and submitting all mandatory reports to relevant authorities, which may include but are not limited to:

  • The Office of Financial Sanctions Implementation (OFSI) in the United Kingdom

  • The U.S. Office of Foreign Assets Control (OFAC)

  • Ghana’s Financial Intelligence Centre (FIC)

  • Other applicable national or international regulatory bodies
    ● Throughout this process, the transaction must remain suspended until explicit clearance or guidance is received from the appropriate compliance or regulatory authority.

Clearance Requirement
● Upon identification of any confirmed or suspected match to sanctions lists, involvement in restricted activities, or any other potential compliance risk, all related transactions must be immediately halted.
● No further actions—including but not limited to the release of funds, shipment of goods, or execution of contractual commitments—shall proceed without explicit, written clearance from the designated Compliance Officer.
● In cases requiring regulatory notification or approval, such clearance must also be obtained from the relevant governmental authorities before resuming any transaction-related activities.
● This protocol ensures full compliance with applicable sanctions and export control regulations and mitigates the risk of inadvertent violations or unauthorized dealings.

Compliance Framework

Tide Table Logistics Ltd strictly adheres to all applicable legal and regulatory instruments governing sanctions and export controls, including:

United Kingdom

Tide Table Logistics Ltd strictly complies with the United Kingdom’s Sanctions and Anti-Money Laundering Act 2018 (SAMLA), which serves as the cornerstone legislation empowering the UK government to impose, implement, and enforce financial and trade sanctions. This act allows for the establishment of sanctions regimes targeting individuals, entities, vessels, and countries involved in activities contrary to UK foreign policy or national security interests. The legislation covers a wide spectrum of restrictions including asset freezes, trade prohibitions, immigration bans, and restrictions on financial services. Compliance oversight and enforcement responsibilities rest with the Office of Financial Sanctions Implementation (OFSI), a division within HM Treasury, which issues updated sanctions lists and provides guidance to regulated entities. Tide Table Logistics Ltd ensures all operations within and involving the UK jurisdiction rigorously adhere to the provisions of SAMLA and OFSI directives, thereby preventing any engagement with designated persons or prohibited goods, and avoiding inadvertent breaches through continuous monitoring, screening, and staff training.

United States

Tide Table Logistics Ltd fully complies with the sanctions and export control regulations enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC administers andBucket list enforces economic and trade sanctions based on U.S. foreign policy and national security objectives, targeting countries, regimes, individuals, and entities involved in terrorism, narcotics trafficking, proliferation of weapons of mass destruction, human rights abuses, and other illicit activities. Central to these regulations are the Specially Designated Nationals (SDN) List and sectoral sanctions, which prohibit U.S. persons and entities worldwide from engaging in transactions or providing services with designated individuals, entities, or restricted sectors such as energy, finance, and defense. OFAC sanctions often apply extraterritorially, affecting non-U.S. companies conducting business involving U.S. goods, technology, or currency. Tide Table Logistics Ltd maintains rigorous screening procedures against OFAC’s SDN and other sanctions lists, integrates real-time monitoring of regulatory updates, and ensures all transactions comply with OFAC prohibitions and licensing requirements. The company also implements thorough due diligence processes to identify potential exposure and mitigate risks associated with U.S. sanctions violations, thereby upholding its commitment to lawful and ethical global trade.

European Union

Tide Table Logistics Ltd complies with the comprehensive sanctions and restrictive measures enacted by the European Union under its Common Foreign and Security Policy (CFSP). The EU’s sanctions framework consists of Council Regulations and Decisions that implement restrictive measures such as asset freezes, trade embargoes, travel bans, and financial restrictions targeting individuals, entities, and countries involved in activities undermining international peace and security. These sanctions are often aligned with United Nations Security Council Resolutions but may also reflect autonomous EU foreign policy objectives. The EU sanctions cover a wide range of sectors including arms, energy, finance, and dual-use goods, with strict controls on exports and transshipments through EU territory or involving EU persons and companies. Tide Table Logistics Ltd ensures full compliance by integrating EU sanctions screening at multiple operational points, maintaining up-to-date knowledge of regulatory changes via official EU channels, and conducting thorough due diligence to prevent transactions involving restricted parties or embargoed commodities. This adherence reinforces the company’s dedication to international legal standards and ethical trade practices across its global operations.

United Nations

Tide Table Logistics Ltd strictly adheres to the sanctions regimes established by the United Nations Security Council (UNSC) under Chapter VII of the UN Charter. These Security Council Resolutions impose mandatory and legally binding measures on all UN member states, including asset freezes, trade embargoes, arms restrictions, travel bans, and other targeted sanctions aimed at maintaining or restoring international peace and security. The UN sanctions are designed to address issues such as the proliferation of weapons of mass destruction, terrorism, human rights abuses, and conflicts in designated regions or countries. Compliance with these resolutions is obligatory and requires states to enact domestic legislation and enforcement mechanisms to prevent prohibited transactions and activities. Tide Table Logistics Ltd integrates these global mandates into its compliance framework by continuously monitoring updated UN sanctions lists, conducting rigorous due diligence on all parties and shipments, and suspending any transaction that risks breaching these international obligations. This ensures that the company not only meets its legal responsibilities but also contributes to the broader global effort to uphold peace, security, and lawful trade practices.

Ghana

Tide Table Logistics Ltd complies fully with the export control regulations and sanctions guidance issued by the Ghana Ministry of Trade and Industry, as well as relevant directives and advisories from the Financial Intelligence Centre (FIC) of Ghana. These national frameworks establish the legal basis for regulating the export, import, and transit of goods, particularly strategic commodities such as petroleum products, precious minerals, and dual-use items that may have military or proliferation risks. The Ministry of Trade enforces licensing requirements, embargoes, and restrictions on trade with designated countries or entities to safeguard Ghana’s economic and national security interests. Concurrently, the FIC plays a critical role in detecting, preventing, and reporting suspicious financial transactions linked to money laundering, terrorism financing, and other illicit activities that may intersect with sanctions violations. Tide Table Logistics Ltd integrates these domestic controls into its operational processes through mandatory screening, classification of goods, transaction monitoring, and cooperation with national regulatory bodies. This ensures that all export-related activities conducted within or through Ghanaian jurisdiction adhere to the highest standards of legal compliance and support the country’s commitment to international trade security and anti-corruption efforts.

In addition to these legal frameworks, Tide Table Logistics Ltd integrates industry best practices and standards derived from leading organizations such as the International Chamber of Commerce (ICC), the Baltic and International Maritime Council (BIMCO), and Lloyd’s of London. These frameworks help ensure that the company maintains a robust, ethical, and globally recognized compliance posture in its operations.

Recordkeeping & Audit

● All documentation and records pertaining to sanctions and export control compliance activities—including, but not limited to, sanctions screening logs, escalation reports, risk assessments, due diligence findings, transaction clearance approvals, and correspondence with regulatory authorities—must be securely retained for a minimum period of five (5) years from the date of the related transaction or compliance decision.
● These records shall be stored in a manner that preserves their confidentiality, accuracy, and integrity, ensuring that they remain readily accessible for internal audits, regulatory inspections, or external legal reviews, while protecting sensitive business and client information in accordance with data privacy laws and company policies.
● The Compliance Department shall conduct regular, systematic audits at defined intervals to verify adherence to this Sanctions & Export Controls Compliance Policy. These audits will assess the adequacy and effectiveness of sanctions screening processes, escalation procedures, staff training, and recordkeeping practices. They will also identify compliance gaps, emerging risks, or weaknesses within the existing control environment.
● Findings from these audits, including identified deficiencies and recommended corrective actions, shall be formally documented and reported to senior management and relevant stakeholders. The Compliance Department will oversee the timely implementation of remediation measures and monitor progress to ensure continuous enhancement of Tide Table Logistics Ltd’s sanctions and export control compliance program.

Enforcement

● Any employee, contractor, or agent of Tide Table Logistics Ltd who knowingly violates applicable sanctions laws, engages in prohibited transactions, or fails to promptly identify and escalate potential sanctions or export control risks will be subject to disciplinary action. Such disciplinary measures may range from formal warnings and mandatory retraining to suspension, demotion, or termination of employment or contractual relationships, depending on the severity and circumstances of the violation.

● The company maintains a zero-tolerance stance on non-compliance with sanctions and export control regulations, recognizing that breaches can expose Tide Table Logistics Ltd to substantial legal penalties, financial losses, and reputational damage.
● In addition to internal disciplinary processes, any confirmed violations or suspicious activities that potentially contravene applicable sanctions or export control laws will be reported, as required by law, to the relevant governmental and regulatory authorities, such as the Office of Financial Sanctions Implementation (OFSI) in the UK, the U.S. Office of Foreign Assets Control (OFAC), the Financial Intelligence Centre (FIC) in Ghana, or other appropriate enforcement bodies.
● The company will fully cooperate with investigations or inquiries initiated by regulatory agencies or law enforcement authorities, providing necessary documentation and support to ensure transparency and compliance with legal obligations.