Sanctions policy.

Last updated: 14 May 2026 · Document ID: BB-GROUP-PROFILE-2026-V6 · Validity: 12 months from issue.

1. Applicable regimes

The Group monitors and applies, without limitation, the following sanctions regimes:

1. United States — Office of Foreign Assets Control (OFAC), Specially Designated Nationals and Blocked Persons List (SDN), Sectoral Sanctions Identifications List (SSI), Non-SDN Menu-Based Sanctions List, and country-specific programs.
2. European Union — consolidated list of persons, groups, and entities subject to EU financial sanctions.
3. United Nations — UN Security Council Consolidated List.
4. United Kingdom — Office of Financial Sanctions Implementation (OFSI) consolidated list under the Sanctions and Anti-Money Laundering Act 2018.
5. People’s Republic of China — Unreliable Entity List and applicable countermeasures.

2. Counterparty screening

All counterparties — producers, titleholders, refineries, storage operators, logistics providers, institutional buyers, offtakers, banks, and accredited intermediaries — are screened at onboarding and on an ongoing basis. Screening covers the legal counterparty, its ultimate beneficial owners (UBOs), its directors and officers, and any material related parties. Sanctions hits are escalated to senior management and the engagement is suspended pending review.

3. Denied parties

The Group does not knowingly enter into business with, facilitate transactions for, or provide services to any person, entity, or organisation that is:

1. Listed on any applicable consolidated sanctions list referenced in Section 1.
2. Owned or controlled, directly or indirectly, 50% or more (in aggregate) by one or more listed persons (OFAC 50% Rule and equivalent EU / UK aggregation rules).
3. Acting on behalf of a listed person.
4. Otherwise the subject of applicable sectoral or activity-based sanctions that would prohibit the proposed engagement.

4. Jurisdictional restrictions

The Group will not advance transactions originating in, transiting through, or destined for jurisdictions that are subject to comprehensive sanctions under any of the regimes referenced in Section 1, including (as of the date of this policy) the Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia regions of Ukraine, the Democratic People’s Republic of Korea (DPRK), the Islamic Republic of Iran, the Syrian Arab Republic, and Cuba, except where a specific licence or general authorisation permits the activity and the engagement is consistent with applicable law in every jurisdiction concerned.

5. End-use and end-user verification

For commodities in the licensed strategic-trade category — security technologies, controlled categories, dual-use goods — the Group requires end-user verification, end-use statements, and where applicable export licences from the originating jurisdiction. Such transactions are advanced only where lawful, licensed, end-user verified, and sanctions-cleared, consistent with the Group’s published commodity-trade discipline.

6. Banking and settlement

Transactions are settled only through bank routes that are themselves compliant with the applicable sanctions regimes. The Group requires bankable proofs of funds (POF) and verifiable proofs of product (POP). Non-bankable, informal, or otherwise unsupported settlement instructions are rejected.

7. Reporting and recordkeeping

The Group will report blocked or rejected transactions to the competent authority where required by applicable law (for example, OFAC reporting requirements for blocked property and rejected transactions). Sanctions screening records are retained for a minimum of seven (7) years from the end of the engagement, in line with the Group’s AML / CFT framework.

8. Updates to this policy

Sanctions lists and regimes change frequently. The Group monitors changes through commercially-available screening tools and through bank and counsel advisories. This policy reflects the Group’s position as of the date above and may be updated without notice. The current version is published at /legal/sanctions-policy.html.