OFAC & International Sanctions Disclosure

XRT Group LLC is fully committed to compliance with all applicable economic and trade sanctions programs administered by the U.S. Office of Foreign Assets Control (OFAC) and other international sanctions authorities.

1. Commitment to Sanctions Compliance

XRT Group LLC (“XRT,” “we,” “us,” or “our”) maintains a rigorous, globally integrated sanctions compliance program designed to ensure full adherence to all applicable economic and trade sanctions laws, regulations, and executive orders. This includes, but is not limited to, sanctions programs administered and enforced by:

• U.S. Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury
• U.S. Department of Commerce, Bureau of Industry and Security (BIS) — Export Administration Regulations (EAR)
• U.S. Department of State, Directorate of Defense Trade Controls (DDTC) — International Traffic in Arms Regulations (ITAR)
• United Nations Security Council (UNSC) sanctions resolutions
• European Union (EU) Common Foreign and Security Policy (CFSP) sanctions
• United Kingdom Office of Financial Sanctions Implementation (OFSI), HM Treasury
• Monetary Authority of Singapore (MAS) sanctions regulations
• Any other sanctions authority with jurisdiction over XRT's operations, counterparties, or transactions

2. OFAC Overview

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. OFAC sanctions target:

• Foreign countries and regimes (comprehensive and limited sanctions programs)
• Terrorists and terrorist organizations
• International narcotics traffickers
• Those engaged in activities related to the proliferation of weapons of mass destruction
• Specially Designated Nationals and Blocked Persons (SDNs)
• Entities owned or controlled by sanctioned persons or governments
• Other threats to the national security, foreign policy, or economy of the United States

3. Sanctions Screening Program

XRT implements a comprehensive sanctions screening program applicable to all counterparties, transactions, trade routes, vessels, financial institutions, and intermediaries.

3.1 Screening Scope

We screen the following against all applicable sanctions lists:

• All prospective and existing counterparties (buyers and suppliers)
• Ultimate Beneficial Owners (UBOs) holding 10% or more
• Directors, officers, and authorized signatories
• Intermediaries, agents, brokers, and representatives
• Financial institutions involved in transactions (issuing banks, confirming banks, correspondent banks)
• Vessels, shipping companies, and vessel owners/operators
• Ports of loading, discharge, and transit
• Countries of origin, destination, and transit for goods and funds
• End-users and end-use of commodities

3.2 Key Sanctions Lists

Our screening program includes, at minimum, the following lists:

3.3 Screening Frequency

• Initial screening: Prior to onboarding any new counterparty or entering into any transaction
• Pre-transaction screening: Prior to issuance or acceptance of any Confirmation, shipment, or payment
• Ongoing screening: Periodic re-screening of all active counterparties (minimum quarterly) and ad-hoc re-screening upon sanctions list updates
• Event-driven screening: Upon changes in ownership, UBO, or control of any counterparty

4. Prohibited Activities

XRT strictly prohibits:

1. Engaging in any transaction, directly or indirectly, with any person, entity, organization, vessel, or country that is the target of sanctions administered by OFAC, the UN, the EU, the UK, Singapore, or any other applicable sanctions authority.
2. Facilitating, arranging, or brokering any transaction that would circumvent or evade applicable sanctions, including through the use of third-party intermediaries, shell companies, complex corporate structures, or alternative trade routes.
3. Exporting, re-exporting, or transferring any commodities, products, technology, software, or services to sanctioned destinations, entities, or individuals, or for sanctioned end-uses, without the required licenses or authorizations from the relevant government authorities.
4. Dealing in property or interests in property of any blocked person, or making any funds, goods, or services available to or for the benefit of any blocked person.
5. Engaging in any transaction involving a country or territory subject to comprehensive sanctions programs unless explicitly authorized by a general or specific license issued by the relevant sanctions authority.

5. Sanctions Programs by Jurisdiction

As a U.S.-headquartered company with operations in the Netherlands and Singapore, XRT navigates a complex and overlapping set of sanctions regimes. Key considerations include:

5.1 U.S. Sanctions (Primary)

As a U.S. company, XRT is subject to U.S. sanctions laws regardless of where in the world a transaction takes place. U.S. sanctions apply to:

• All U.S. persons (citizens, permanent residents, and entities) wherever located
• Transactions conducted in or through the United States
• Transactions involving U.S.-origin goods, technology, or services
• Transactions denominated in U.S. Dollars (in certain circumstances)

5.2 EU Sanctions (Rotterdam Hub)

XRT's Rotterdam operations are subject to EU sanctions regulations, which may differ in scope from U.S. sanctions. We implement controls to ensure compliance with both U.S. and EU sanctions regimes, following the more restrictive standard where conflicts arise, subject to applicable blocking statutes (e.g., EU Blocking Regulation — Council Regulation (EC) No 2271/96).

5.3 Singapore Sanctions Hub

XRT's Singapore operations comply with UNSC sanctions as implemented under Singapore law through the UN Act, as well as MAS-administered financial sanctions. Singapore does not implement unilateral sanctions but strictly enforces UNSC-mandated measures.

6. Reporting & Escalation

XRT personnel are required to immediately report any actual or suspected sanctions violation, or any attempt by a counterparty to evade sanctions, to the Compliance Officer. Reports may be made directly or through XRT's whistleblowing channels. All reports are investigated promptly, and appropriate action is taken, which may include:

• Internal investigation and documentation
• Voluntary self-disclosure to the relevant sanctions authority (e.g., OFAC, OFSI)
• Blocking or rejecting the transaction
• Termination of the business relationship
• Remedial measures to strengthen controls

XRT may voluntarily self-disclose apparent sanctions violations to the relevant authorities. Under OFAC's Enforcement Guidelines, voluntary self-disclosure is considered a mitigating factor in determining any enforcement response.

7. Third-Party and Counterparty Representations

By entering into any transaction or business relationship with XRT, each counterparty represents and warrants that:

1. Neither the counterparty nor any of its directors, officers, employees, agents, UBOs, or affiliates is a Sanctioned Person (as defined below) or located, organized, or resident in a country or territory subject to comprehensive sanctions.
2. The counterparty shall not, directly or indirectly, use, transfer, sell, export, or re-export any commodities, products, funds, or services provided by XRT in connection with any Sanctioned Person or Sanctioned Territory, or for any purpose prohibited by applicable sanctions laws.
3. The counterparty shall provide accurate and complete information regarding the end-use, end-user, and ultimate destination of all commodities purchased from or sold to XRT.
4. The counterparty shall immediately notify XRT if it becomes a Sanctioned Person or if any representation herein ceases to be true.

For purposes of this disclosure, a “Sanctioned Person” means any person or entity that is (a) listed on any applicable sanctions list, including the OFAC SDN List, the UN Consolidated List, the EU Consolidated List, or the UK Sanctions List; (b) organized, domiciled, or resident in a Sanctioned Territory; or (c) 50% or more owned, directly or indirectly, by one or more persons described in (a) or (b) above, or otherwise controlled by such persons.

8. Licenses & Exceptions

In certain circumstances, transactions that would otherwise be prohibited by sanctions may be authorized by general or specific licenses issued by the relevant sanctions authority. XRT may, at its sole discretion and after careful legal and compliance review, apply for specific licenses or rely on general licenses where legally permissible. XRT is under no obligation to pursue or seek any such authorization.

9. Training & Awareness

XRT provides sanctions compliance training to all relevant personnel, covering:

• Overview of applicable sanctions programs and authorities
• OFAC regulatory framework and SDN list
• Red flags and indicators of sanctions evasion (including common typologies)
• Screening procedures and escalation protocols
• Consequences of sanctions violations (civil and criminal penalties)

Training is conducted at least annually, with role-specific training for higher-risk functions.

10. Penalties for Non-Compliance

Violations of U.S. sanctions laws can result in severe civil and criminal penalties. Under the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA):

• Civil penalties: Up to the greater of $356,579 per violation or twice the value of the underlying transaction (adjusted annually for inflation)
• Criminal penalties: Up to $1,000,000 in fines and up to 20 years imprisonment for willful violations
• Additional consequences: Loss of export privileges, debarment from government contracting, reputational damage, and designation as a sanctions violator

Similar penalties exist under EU, UK, Singapore, and UN sanctions regimes. XRT is committed to full compliance and has zero tolerance for sanctions violations by any employee, contractor, or business partner.

11. OFAC 50% Rule

Consistent with OFAC guidance, XRT applies the “50% Rule” when screening counterparties. Under this rule, any entity that is owned 50% or more, directly or indirectly, in the aggregate by one or more blocked persons is itself considered a blocked person, regardless of whether it is listed on the SDN List. XRT's screening process and counterparty due diligence are designed to identify such aggregated ownership structures.

Contact

For questions about this OFAC Disclosure, to report concerns regarding potential sanctions violations, or to request additional information:

© 2026 XRT Group LLC. This OFAC & Sanctions Disclosure is reviewed and updated at least annually and upon material changes to applicable sanctions programs.