AML · CTF · Sanctions Policy
Zero tolerance for bribery, corruption & financial misconduct
Statement of Ethics
PetroSing Energy Pte. Ltd. is committed to conducting its oil and gas trading activities with the highest standards of integrity, transparency, and professionalism. Our reputation as a trusted trading partner is built on honesty, fairness, and strict adherence to applicable laws and regulations.
We maintain zero tolerance for bribery, corruption, sanctions evasion, money laundering, or any improper business conduct. All transactions must comply with applicable international trade controls, including U.S., UN, EU, UK, Singapore, and other relevant sanctions regimes.
We expect our counterparties, intermediaries, and suppliers to uphold the same ethical standards and regulatory discipline. Strong compliance and responsible business practices form the foundation of our long-term, sustainable commercial relationships.
Policy Areas
All personnel must comply with Singapore laws and international standards, avoid conduct that could harm the Company's reputation, and escalate compliance concerns immediately.
The Board appoints a designated Compliance Officer (CO) with authority to approve or veto any transaction, suspend suspicious activities, file SARs/STRs, and report directly to the CEO and Board. All staff undergo annual AML, Sanctions, and Anti-Bribery training. An independent external review is conducted every 24 months.
The Company strictly prohibits involvement in money laundering, terrorist financing, and trade-based money laundering. No trade shall proceed without proper counterparty onboarding. The Company adopts a Risk-Based Approach concentrating resources on high-value cargoes, cross-border payments, and high-risk jurisdictions.
No trade may be executed until the counterparty has been formally onboarded. Three tiers apply: Simplified Due Diligence (SDD) for low-risk entities, Standard CDD for most private companies, and Enhanced Due Diligence (EDD) requiring Compliance Officer approval for high-risk cases.
Zero tolerance toward sanctioned entities. All counterparties, banks, brokers, and vessels must be screened against UN, U.S. OFAC, EU, UK, and Singapore sanctions lists. Absent express legal authorization, no transactions may involve Iran, North Korea, Russia, Syria, Venezuela, or Cuba.
For physical oil trades, vessel name and IMO number must be screened, ownership verified, and AIS history reviewed. The Company will not use vessels that called at sanctioned ports within the last 24 months or that exhibit AIS manipulation or "dark activity".
The Company prohibits offering or accepting bribes, kickbacks, and facilitation payments. Gifts and hospitality must be reasonable, transparent, and properly recorded. Third-party agents must undergo due diligence prior to engagement.
Employees must immediately notify the Compliance Officer upon detecting: payment anomalies (requests to pay into unrelated third-country accounts, sudden banking instruction changes), significant price deviations from Brent/WTI/Platts benchmarks without explanation, unnecessary intermediaries or shell companies obscuring end-users, or documentation discrepancies such as mismatches between Bill of Lading, Invoice, and Certificate of Origin.
Counterparty Onboarding
No trade may be executed until the counterparty has been formally onboarded under one of three due diligence levels based on risk profile.
Applicable to:
Requirement: Verify legal existence via corporate registry.
Required documentation:
Applicable to: High-risk jurisdictions, PEPs, complex ownership, high-value transactions.
Documentation & Retention
All records must be stored in a secure, encrypted digital environment. Retained records include KYC files, screening logs, trade confirmations, and compliance approvals.
Suspicious Activity Reporting
If the Compliance Officer determines a transaction is suspicious: (1) the transaction shall be frozen immediately, (2) an internal review shall be conducted, (3) a SAR/STR shall be filed with the relevant Financial Intelligence Unit (FIU).
Strict anti-tipping off rule applies — no employee may inform a counterparty that a report has been filed.
Non-Retaliation & Disciplinary Action
Employees may report concerns confidentially. Retaliation against good-faith reporting is strictly prohibited. Violations of this Policy may result in immediate termination, civil liability, and criminal referral. This Policy is reviewed annually or earlier if regulatory requirements or the Company's risk profile materially changes.
"Acting with integrity is not just the right thing to do — it is fundamental to sustaining the markets, relationships, and communities we depend on."
For trading enquiries, partnerships, or general information, please contact our team. We look forward to working with you.
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