Compliance & Sanctions

Trump Oil holds no OFAC licence, authorization, determination, no-action position or interpretive guidance, and has no application pending that has been granted. It has no agreement, allocation, concession or understanding with the government of Venezuela, PDVSA, any Venezuelan state-owned enterprise, or the United States government.

No hydrocarbons have been purchased, lifted, transported, refined, sold or contracted for. No funds have been transmitted to any Venezuelan counterparty.

• The Venezuela Sanctions Regulations, 31 C.F.R. Part 591, and related Executive Orders administered by the U.S. Office of Foreign Assets Control (OFAC).
• The Specially Designated Nationals and Blocked Persons (SDN) List, the Sectoral Sanctions and Non-SDN lists, and the 50 Percent Rule on entities owned by blocked persons.
• U.S. export controls administered by the Bureau of Industry and Security, including the Entity List and end-use controls on refining equipment.
• The Foreign Corrupt Practices Act, U.S. anti-money-laundering law, and equivalent obligations in every other jurisdiction touched by a transaction.
• Venezuelan hydrocarbons, environmental, customs, labour and tax law.

No transaction, payment, commitment, letter of intent or binding negotiation involving Venezuelan hydrocarbons will be entered into unless and until the company holds either a specific OFAC licence covering the activity, or a documented general-licence pathway confirmed in writing by qualified U.S. sanctions counsel.

If authorization is unavailable, refused, revoked or ambiguous, the activity does not proceed. The company will not restructure, layer or route a transaction to reduce the visibility of a sanctions nexus.

• Appointment of a compliance officer accountable for sanctions, export-control and anti-corruption compliance.
• Written sanctions compliance programme aligned to OFAC's Framework for Compliance Commitments: management commitment, risk assessment, internal controls, testing and auditing, and training.
• Restricted-party screening of every counterparty, beneficial owner at or above 25 percent, vessel, agent and payment route, with re-screening at defined intervals.
• Beneficial-ownership and 50 Percent Rule analysis, politically-exposed-person review, and source-of-funds review.
• Vessel and voyage due diligence, including AIS-gap review, ship-to-ship transfer review and flag-history review.
• Contractual sanctions, anti-corruption and audit clauses with termination rights in every agreement.
• Escalation, recordkeeping and voluntary-self-disclosure procedures, with records retained for at least five years.

The company prohibits any payment, gift, hospitality, political contribution or thing of value offered to a government official, state-enterprise employee or intermediary to obtain or retain business or secure an improper advantage. No facilitation payments are permitted. Third-party intermediaries must pass due diligence and accept written anti-corruption obligations.

Suspected sanctions or corruption issues should be reported through the Request Information form. The company intends to maintain a confidential, non-retaliatory reporting channel before any operational activity begins.

This document is a draft prepared internally for a development-stage concept. It is not legal advice and must be reviewed and approved by qualified counsel before the company relies on it or represents it as final.

Extra-heavy crude handling, diluent use, upgrading and refining carry material environmental, health and safety risk: air emissions including sulphur compounds and volatile organics, greenhouse-gas intensity above light-crude baselines, process water and effluent discharge, sludge and catalyst waste, soil and groundwater contamination, spill and fire risk, and cumulative impacts on nearby communities.

The company does not represent that these risks are small, solved, or offset. No environmental or social impact assessment has been commissioned.

• Independent Environmental and Social Impact Assessment by a qualified third party, scoped to international lender standards such as the IFC Performance Standards and the Equator Principles.
• Baseline air, water, soil, biodiversity and community-health studies before any site work.
• Permits and permitted limits from every competent authority, with no construction before issuance.
• Free, prior and informed consultation with affected and indigenous communities, and a documented grievance mechanism.
• Quantified flaring, venting and methane-management commitments, with measurement rather than estimation.
• Water balance and effluent treatment plan, with discharge limits and monitoring points published.
• Waste, sludge and spent-catalyst management plan with licensed disposal chains.
• Spill prevention, containment and emergency-response plan, tested with local responders.
• Financial assurance for closure, remediation and third-party damage, sized independently.
• Independent monitoring with public reporting at defined intervals.

If an assessment concludes that impacts cannot be avoided, minimised or mitigated to permitted limits, or if financial assurance or independent monitoring cannot be put in place, the relevant activity does not proceed. Environmental conditions are not treated as negotiable commercial terms.

This document is a draft prepared internally for a development-stage concept. It is not legal advice and must be reviewed and approved by qualified counsel before the company relies on it or represents it as final.