AML, KYC and Sanctions Policy

1. Commitment

LAMERZA SHIPPING SERVICES Sp. z o.o. maintains an anti-money laundering (AML) and counter-terrorist financing (CTF) programme and applies it to every business relationship. We will not allow our services to be used for money laundering, terrorist financing, fraud, corruption, sanctions evasion or any other criminal activity.

2. Customer due diligence (KYC)

Before onboarding, corporate customers provide:

• Certificate of incorporation or commercial register extract
• VAT registration details
• Company articles and shareholder structure
• Ultimate beneficial owner (UBO) information
• Identity documents of directors and authorised signatories
• Proof of business address
• Corporate bank account details

3. Source of funds and source of wealth

Where the transaction profile requires it, we ask for evidence that funds come from lawful sources — for example bank statements, commercial invoices, contracts, audited financial statements or tax filings.

4. Sanctions screening

Customers, counterparties, vessels and destinations are screened against applicable EU, UN, UK and US sanctions lists. We do not do business with sanctioned persons, entities, vessels or jurisdictions, and we screen for dual-use and restricted goods.

5. Politically exposed persons and high-risk cases

Enhanced due diligence is applied to politically exposed persons, their family members and close associates, to complex ownership structures and to counterparties connected with high-risk jurisdictions.

6. Ongoing monitoring and reporting

• Transactions are monitored against the customer's declared business profile
• Additional documentation may be requested at any time
• Transactions may be delayed, refused or terminated
• Suspicious activity is reported to the competent Polish authorities where the law requires it
• Records are retained for 5 years after the end of the business relationship

7. Contact

Compliance and due diligence questions, including requests for our documentation pack, are handled at info@lamerza-poland.com.