Sanctions & Export Control

This Policy applies to FSC personnel, entities and relevant third parties involved in sales, booking, cargo acceptance, routing, payments and delivery. Trade controls vary by jurisdiction and change over time.

Each business owner must identify applicable restrictions and obtain Compliance advice before committing FSC to a transaction where a control may apply.

FSC will not knowingly facilitate a transaction prohibited by applicable sanctions or export-control law. Restrictions may concern countries, territories, persons, entities, vessels, goods, technology, services or end uses.

No employee may restructure, reroute, misdescribe or conceal a transaction to evade a restriction, screening control or reporting obligation.

Relevant customers, beneficial owners, counterparties, banks, agents, vessels and other parties must be screened using approved processes at appropriate stages. Screening results must be assessed rather than treated as a substitute for judgement.

Potential matches must be escalated and resolved before proceeding. Document the identifiers reviewed, rationale and approvals, while protecting sensitive information.

Certain goods, software, technical data and services may require a licence, classification or end-use review even when the parties are not listed. Accurate product descriptions and supporting documents are essential.

Do not accept instructions to alter cargo descriptions or provide restricted technical information without authorisation. Seek specialist advice where classification or destination is uncertain.

The full route and transport chain must be considered, including ports of loading, discharge and transhipment, vessel operators and any relevant maritime restrictions. A change in route can change the risk assessment.

Unusual routing, opaque ownership, ship-to-ship transfers or requests to omit route details are warning signs. Pause the transaction and refer it to Compliance.

Collect and retain sufficient information to understand the parties, cargo, origin, destination, end user, intended use and payment flow, proportionate to risk and law.

Customers and partners must provide complete, truthful information and promptly notify FSC of material changes. Incomplete or inconsistent documentation may lead to a hold or refusal.

Where a licence or government authorisation is required, the responsible team must verify its scope, conditions, validity and applicability before performance. A licence must not be assumed to cover a different party, product or route.

Maintain the authorisation and evidence of compliance with its conditions. Escalate any proposed deviation or uncertainty before cargo acceptance or release.

Where a potential restriction or red flag is identified, place the transaction on hold as appropriate, preserve records and contact Compliance. Only an authorised decision-maker may release a hold.

Do not disclose a confidential screening decision or make a prohibited disclosure. Compliance will coordinate legal review and any required government reporting.

Screening decisions, licences, approvals, communications and transaction records must be retained under applicable law and FSC schedules. Personnel in relevant roles must complete assigned training.

Report concerns or seek guidance at compliance@fastsafecargo.com. FSC may suspend or decline business where legal risk cannot be resolved.