Version 1.0 · Summary of the policy applied by Rathmar Trading, LLC and its offices in Houston and Zurich. The full policy is provided to counterparties on request.
Rathmar applies the sanctions and export-control measures of the United States (OFAC, the Export Administration Regulations administered by BIS, and the International Traffic in Arms Regulations), the UN Security Council, the European Union, the United Kingdom and Switzerland (SECO). Where regimes differ, the strictest rule that applies to a transaction governs it.
We do not deal, directly or indirectly, with persons designated under these regimes or with entities owned 50 percent or more, individually or in aggregate, or controlled by them. We do not trade into or out of comprehensively sanctioned countries or regions. We do not structure transactions to avoid sanctions, and we do not remove or alter payment or shipping information.
Counterparties, their ultimate beneficial owners, directors and banks, and the vessels, ports, agents and cargoes involved in a trade are screened before a contract is signed, again at vessel nomination, before loading and before payment, and throughout the relationship. Screening covers the OFAC SDN and sectoral lists, the BIS Entity, Denied Persons, Unverified and Military End-User lists, and the EU, UK, UN and SECO lists.
Vessels are checked for ownership, management, flag history and AIS record. Unexplained AIS gaps, ship-to-ship transfers in high-risk areas, frequent re-flagging and opaque ownership are escalated to Compliance, in line with the maritime guidance issued by OFAC, the UK and the EU.
Trade connected to a jurisdiction subject to targeted measures proceeds only where it is permitted, including under a general or specific licence or a humanitarian exemption. Such trade requires enhanced due diligence on the counterparty, its owners and the end user; documented end-use and end-user statements; delivery verification; and written Compliance sign-off. Licence conditions are recorded and monitored through to final delivery.
Goods are classified before shipment under the EAR (ECCN or EAR99), the EU Dual-Use Regulation and Swiss export-control law, and licences are obtained where required. We check for military end use and end users and do not supply goods that could support weapons programs.
Our contracts include sanctions and export-control warranties, end-use and no-diversion undertakings, and a right to suspend or terminate where performance would breach an applicable measure.
Possible matches, red flags and suspected breaches are escalated to Compliance, which decides whether a trade may proceed and whether a report or voluntary disclosure to an authority is required. Screening and licensing records are kept for at least ten years.
Traders, operators and finance staff are trained on joining and every year after. Concerns may be reported to Compliance or at speakup@rathmar.com.