Anti-Money Laundering (AML) Notice

§1. Purpose & Scope

This Notice applies to all customers, transporters, vendors, agents, and counterparties who engage Seaway Export for the purchase, procurement, transportation, export, or forwarding of vehicles, machinery, boats, and general cargo. It governs the onboarding, screening, and ongoing monitoring we perform to ensure our services are not used to launder proceeds of crime or to evade trade sanctions and export controls.

By transacting with Seaway Export, you acknowledge that we may request identifying information and documentation, screen the parties and cargo involved, and decline, pause, or report any transaction that presents an unacceptable legal or compliance risk.

§2. Regulatory Framework

Our compliance program is designed to align with applicable U.S. and international laws and regulations, including but not limited to:

• The Bank Secrecy Act (BSA) and related U.S. Treasury / FinCEN regulations
• The USA PATRIOT Act and anti-terrorist financing requirements
• Sanctions programs administered by the U.S. Office of Foreign Assets Control (OFAC)
• The Export Administration Regulations (EAR) enforced by the U.S. Bureau of Industry and Security (BIS)
• U.S. Customs and Border Protection (CBP) and Automated Export System (AES) requirements
• Applicable international standards, including the Financial Action Task Force (FATF) recommendations

Where local law in a customer's jurisdiction imposes additional obligations, we work to observe those requirements as well.

§3. Customer Due Diligence (KYC)

As part of our Know Your Customer (KYC) procedures, we may collect and verify:

• Full legal name, business name, and registration or incorporation details
• Physical address, contact information, and country of residence or operation
• Government-issued identification for individuals and beneficial owners
• Nature of the transaction and intended destination of the cargo
• Source of funds and payment method where risk factors warrant

Enhanced due diligence may be applied to higher-risk customers, jurisdictions, or transactions. We reserve the right to refuse service where identity cannot be reasonably verified or where a customer declines to provide required information.

§4. Sanctions & Export-Control Screening

Before and during the course of a transaction, we screen relevant parties, vessels, and destinations against applicable sanctions and denied-party lists, including:

• OFAC Specially Designated Nationals (SDN) and Consolidated Sanctions lists
• BIS Entity List, Denied Persons List, and Unverified List
• Other applicable restricted-party and embargoed-country lists

Seaway Export does not knowingly provide services involving sanctioned individuals, entities, or jurisdictions, or the export of controlled items without required authorization. A positive or potential match may result in the suspension of a transaction pending review.

§5. Prohibited & High-Risk Activity

We will not facilitate, and customers must not attempt to use our services for:

• Laundering proceeds of criminal activity or concealing the origin of funds
• Financing terrorism or proliferation of weapons
• Evading sanctions, export controls, customs duties, or trade restrictions
• Structuring payments or shipments to avoid reporting thresholds
• Providing false, misleading, or incomplete shipment, ownership, or valuation information
• Transacting through undisclosed third parties to obscure the true buyer, seller, or destination

§6. Payment & Transaction Controls

To reduce financial-crime risk, Seaway Export applies controls to how payments are made and received. We may:

• Require payment from an account held in the name of the verified customer
• Decline anonymous, third-party, or unexplained payments
• Limit or scrutinize cash and cash-equivalent transactions
• Request documentation supporting the source and purpose of funds

Transactions that cannot be reconciled with the customer's stated activity may be delayed, returned, or reported as required by law.

§7. Reporting & Recordkeeping

Where required by applicable law, Seaway Export maintains records of customer identification, transactions, and screening results, and reports suspicious activity to the relevant authorities. Consistent with legal requirements:

• Records are retained for the periods mandated by applicable regulations
• Suspicious activity may be reported without prior notice to the customer
• We are generally prohibited from "tipping off" a party that a report has been or may be filed

§8. Training & Internal Controls

Seaway Export maintains internal policies and procedures reasonably designed to detect and prevent money laundering, sanctions evasion, and export-control violations. These include:

• Risk-based onboarding and monitoring procedures
• Periodic staff training on AML, sanctions, and export-control obligations
• Escalation channels for reporting potential red flags
• Periodic review of the compliance program against regulatory developments

§9. Cooperation with Authorities

Seaway Export cooperates with law enforcement, customs, and regulatory authorities in connection with lawful requests, investigations, and reporting obligations. We may share information about a transaction or party with such authorities to the extent permitted or required by applicable law.

§10. Contact & Compliance Officer

For questions about this Notice or to provide compliance-related documentation, contact our Compliance team: