Effective Date: 02/03/2026
Website: www.odaspetroleum.com
ODAS Star Petroleum Trading LLC is committed to conducting business in accordance with the highest ethical standards and in full compliance with applicable anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions regulations.
This policy outlines the framework under which the Company prevents money laundering, terrorist financing, fraud, corruption, and other illicit activities.
1. Policy Statement
ODAS Star Petroleum Trading LLC maintains a zero-tolerance approach toward money laundering and financial crime.
We implement robust compliance procedures to ensure that all counterparties, transactions, and financial flows are legitimate, transparent, and compliant with applicable laws.
2. Scope
This policy applies to:
• All directors and management
• Employees and representatives
• Commercial partners
• Suppliers and logistics providers
• Buyers and trading counterparties
It applies to all business activities, including crude oil trading, Diesel EN 590 supply, Jet Fuel A1 transactions, petrochemical trading, logistics coordination, and related financial arrangements.
3. Regulatory Framework
The Company adheres to applicable:
• United Arab Emirates AML regulations
• Federal Decree-Law No. 20 of 2018 (UAE AML Law)
• Executive Regulations and related guidance
• International compliance standards
• Applicable United Nations sanctions
• European Union sanctions (where applicable)
• Relevant international financial compliance standards
4. Know Your Customer (KYC) Procedures
Before entering into any transaction, the Company conducts strict due diligence procedures.
These include:
Corporate Verification
• Trade license validation
• Corporate registration documents
• Articles of incorporation
• Shareholder and ownership structure
Beneficial Ownership Identification
• Identification of Ultimate Beneficial Owners (UBOs)
• Verification of controlling interests
Identity Verification
• Passport copies of directors
• Government-issued identification
• Proof of business address
Sanctions Screening
• Screening against international sanctions lists
• Politically Exposed Persons (PEP) checks
• Adverse media screening
Source of Funds Verification
• Bank references
• Proof of financial capability
• Transaction purpose validation
The Company reserves the right to request additional documentation at any time.
5. Risk-Based Approach
ODAS Star Petroleum Trading LLC applies a risk-based approach to AML compliance.
Risk factors considered include:
• Country of operation
• Sanctions exposure
• Transaction size
• Payment structure
• Use of intermediaries
• Complex ownership structures
Higher-risk transactions are subject to enhanced due diligence procedures.
6. Transaction Monitoring
The Company monitors transactions to identify unusual or suspicious patterns, including:
• Unusual payment methods
• Inconsistent documentation
• Third-party payments without justification
• Rapid changes in contractual structures
• Attempts to bypass compliance procedures
Any suspicious activity may result in transaction suspension or termination.
7. Prohibited Activities
The Company strictly prohibits:
• Transactions involving sanctioned entities
• Concealment of beneficial ownership
• False documentation
• Structuring payments to avoid regulatory review
• Third-party payments without transparency
• Engagement with shell entities lacking economic substance
8. Record Keeping
All due diligence documentation and transaction records are securely maintained for the legally required retention period.
Records include:
• KYC documentation
• Contracts
• Inspection certificates
• Payment confirmations
• Compliance screening reports
9. Reporting and Escalation
If suspicious activity is identified, the Company may:
• Conduct internal review
• Request additional documentation
• Report to relevant regulatory authorities if required
• Terminate discussions or agreements
10. Employee Awareness
Management ensures that relevant personnel understand AML obligations and compliance standards.
Compliance awareness is integrated into commercial operations and transaction approval processes.
11. Refusal of Business
ODAS Star Petroleum Trading LLC reserves the absolute right to decline any transaction that:
• Fails compliance checks
• Presents elevated financial crime risk
• Involves sanctioned jurisdictions
• Lacks transparency
Business integrity takes precedence over commercial opportunity.
12. Policy Review
This AML & KYC Policy is reviewed periodically and updated when necessary to reflect regulatory changes or operational adjustments.
13. Contact Information
For compliance inquiries:
ODAS Star Petroleum Trading LLC
Office B-81, Malek Khaled Mohammed Abda Al Zahed
Hor Al Anz, Dubai, United Arab Emirates
Phone: +971 503 956 811
Email: office@odaspetroleum.com