1. Purpose of this Disclaimer

Maritime transactions may involve multiple intermediaries, unclear authority chains, beneficial ownership questions, sanctions exposure, payment risk, forged documents, false mandates, and unclear counterparty roles.

RdM’s business discipline is built around clarity before commitment. We may therefore request basic counterparty information, authority confirmation, mandate evidence, business background, and supporting documents before we circulate vessel details, approach owners, introduce parties, support chartering enquiries, or proceed with selected advisory or broking matters.

This disclaimer explains the purpose, limits, and handling of such checks.

2. Scope

This disclaimer applies to KYC / KYB, sanctions, counterparty, mandate, and authority-chain review carried out in connection with RdM’s work.

3. What KYC / KYB Means in RdM’s Context

In this disclaimer, KYC means “Know Your Customer” or basic identity / role understanding for individuals, and KYB means “Know Your Business” or basic understanding of a company, entity, vessel-owning structure, trading party, broker, charterer, buyer, seller, or other business counterparty.

In RdM’s practical maritime context, KYC / KYB may include:

• Understanding who is making the enquiry.
• Confirming the company or entity behind the enquiry.
• Checking whether the person appears authorised to represent the stated party.
• Understanding whether RdM is dealing with a principal, broker, mandate-holder, introducer, consultant, or multiple-layer intermediary.
• Checking whether there are visible sanctions, compliance, fraud, misrepresentation, or authority-chain concerns.
• Assessing whether it is commercially sensible and safe to proceed further.

RdM’s review is proportionate and risk-based. It may be simple for low-risk advisory or desktop-check matters, and more detailed where a transaction involves vessel circulation, owner approach, buyer introduction, chartering exposure, payment risk, sanctions-sensitive trades, or multiple intermediaries.

4. When RdM May Request KYC / KYB Information

RdM may request KYC / KYB or authority-chain information before or during an enquiry where reasonably required. Examples include:

• Before approaching shipowners, sellers, charterers, buyers, or their representatives.
• Before releasing sensitive vessel particulars, seller identity, buyer identity, charterer identity, or pricing information.
• Before recognising or participating in a brokerage chain.
• Before proceeding with a mandate-backed ship sale, purchase, chartering, or project enquiry.
• Where a party claims to be direct with a principal, owner, seller, charterer, or buyer.
• Where payment, deposit, commission, escrow, sanctions, or beneficial ownership risk appears relevant.
• Where the enquiry involves unusual urgency, unclear authority, complex intermediary layers, inconsistent documentation, or high-risk jurisdictions / trades.

RdM may decline, pause, or limit further action if adequate information is not provided or if the authority chain remains unclear.

5. Information RdM May Request

Depending on the nature of the matter, RdM may request some or all of the following:

Please do not send passports, national identification documents, bank statements, account details, crew lists, or highly sensitive personal documents unless specifically requested and unless the purpose and handling basis are clear.

6. Sources Used for Review

RdM may use information provided directly by the client or counterparty, public sources, corporate registries, official websites, maritime databases, vessel databases, sanctions lists, adverse-media searches, professional networks, broker references, and transaction documents to form a practical commercial view.

RdM may also rely on information supplied by counterparties, brokers, clients, owners, charterers, buyers, sellers, consultants, surveyors, financiers, lawyers, insurers, or other transaction participants. RdM does not guarantee that third-party information is complete, accurate, current, or free from misrepresentation.

7. Sanctions, AML & Trade-Control Awareness

Maritime transactions may involve sanctions, trade controls, export controls, AML, vessel-tracking, beneficial ownership, cargo-origin, port-call, flag, classification, insurance, banking, and payment-route considerations.

RdM may perform basic screening or request clarification where sanctions, AML, or trade-control concerns may be relevant. This may include review of names, entities, vessels, beneficial owners, cargo, routes, ports, flags, jurisdictions, payment chains, and transaction participants.

Any such review is a commercial risk-control step only. It is not a legal opinion, sanctions clearance, regulatory approval, bank compliance confirmation, insurance confirmation, or assurance that a transaction is lawful in all relevant jurisdictions.

Where sanctions or compliance questions are material, parties should obtain independent legal, sanctions, banking, insurance, P&I, flag, class, or compliance advice before proceeding.

8. Red Flags & Right to Decline

RdM may pause, decline, limit, or withdraw from an enquiry where red flags are identified or where satisfactory clarification is not provided.

Red flags may include, without limitation:

• Unclear or inconsistent company identity.
• Use of unverifiable business names, personal-only emails, or recently created websites without supporting corporate evidence.
• Reluctance to explain authority chain or mandate basis.
• Multiple intermediary layers with unclear commission recognition.
• Pressure to release vessel, owner, buyer, charterer, or cargo details before basic counterparty comfort is established.
• Suspicious bank letters, account-opening letters presented as proof of funds, or financial documents that do not support the stated commitment.
• Requests involving sanctioned parties, sanctioned vessels, high-risk jurisdictions, deceptive shipping practices, AIS manipulation, cargo-origin concerns, or unusual routing.
• Inconsistent names, addresses, registrations, phone numbers, signatures, or document metadata.
• Requests to bypass normal owner, seller, charterer, or broker procedures.
• Unusual urgency, secrecy, or refusal to provide basic written information.

RdM is not obliged to disclose the full reasoning behind an internal risk decision, particularly where doing so may compromise confidentiality, compliance, legal position, or fraud-prevention controls.

9. Limits of RdM’s Review

KYC / KYB or sanctions-related review by RdM is not exhaustive and does not guarantee that:

• A person or company is legitimate, solvent, authorised, or reliable.
• A mandate is valid, current, exclusive, or enforceable.
• A party has funds, cargo, vessel control, chartering authority, or closing ability.
• A transaction is free of sanctions, AML, fraud, tax, customs, export-control, insurance, banking, or legal risk.
• A bank, owner, charterer, insurer, P&I Club, class society, flag state, port, terminal, financier, regulator, or court will accept the transaction.
• Information provided by third parties is accurate, complete, current, or not misleading.

Each party remains responsible for its own due diligence, approvals, professional advice, internal compliance, legal review, financial assessment, and transaction decision-making.

10. Personal Data, Confidentiality & Document Handling

KYC / KYB review may involve personal data, business contact data, company information, beneficial ownership information, transaction documents, and commercially sensitive records.

RdM handles such information in accordance with its Privacy Policy and Confidentiality Policy, as applicable.

Information may be retained where necessary for legal, regulatory, accounting, tax, audit, compliance, dispute-resolution, anti-fraud, sanctions, AML, record-keeping, or legitimate business purposes.

11. Sharing of KYC / KYB Information

RdM may share KYC / KYB or related information where reasonably necessary for a legitimate business, advisory, broking, transaction, compliance, or legal purpose.

Such sharing may include:

• Internal RdM personnel and support team members who need access to perform the relevant work.
• Professional advisers such as lawyers, accountants, compliance advisers, insurers, or technical consultants.
• Owners, buyers, sellers, charterers, operators, co-brokers, financiers, escrow agents, banks, surveyors, P&I representatives, or other transaction parties where disclosure is necessary and commercially appropriate.
• Service providers supporting email, cloud storage, forms, CRM, website, analytics, payment, document handling, or communications.
• Regulators, courts, law enforcement agencies, government authorities, or other parties where required by law or necessary to protect legal or legitimate business interests.

RdM does not sell personal data or KYC / KYB information.

12. Retention

RdM may retain KYC / KYB records, screening notes, communication records, documents, and related business records for as long as reasonably necessary for the purpose for which they were collected, or for legal, regulatory, compliance, tax, accounting, audit, dispute-resolution, fraud-prevention, sanctions, AML, or legitimate business reasons.

Where a matter does not proceed, RdM may still retain limited records to evidence the enquiry, the basis for non-progression, and any relevant compliance or risk-control decision.

When information is no longer required, RdM will take reasonable steps to delete, anonymise, archive, or securely dispose of it, subject to operational and legal requirements.

13. No Legal, Sanctions, Financial or Compliance Advice

RdM provides commercial maritime advisory and selective broking support. Unless expressly agreed in writing, RdM does not provide legal advice, sanctions advice, AML advice, tax advice, accounting advice, regulated financial advice, insurance advice, customs advice, export-control advice, or formal compliance certification.

Any observations made by RdM regarding a counterparty, company, mandate, vessel, trade, cargo, route, payment structure, or authority chain are practical commercial observations only and should not be relied upon as a substitute for independent professional advice.

14. Changes to this Disclaimer

RdM may update this KYC / KYB & Sanctions Disclaimer from time to time to reflect changes in our services, website, business processes, technology, legal requirements, compliance expectations, or maritime industry practice.

The updated version will be posted on this page with a revised “Last updated” date.

15. Contact

For questions relating to KYC / KYB information, authority-chain clarification, mandate review, or counterparty information handling, please contact:

Please provide sufficient written context for the relevant enquiry. RdM may request further details before considering whether to proceed.