Regulatory Disclosures

Dorax Investment Company Ltd (the "Company") is a private limited liability company incorporated and registered in the Republic of Cyprus under the Cyprus Companies Law, Cap. 113, with registration number HE 412387. The Company's registered office is at Spyrou Kyprianou 61, 4003 Limassol, Cyprus.

The Company is not a bank, credit institution, investment firm, or payment institution. It does not hold a licence from the Cyprus Securities and Exchange Commission (CySEC), the Central Bank of Cyprus, or any other financial regulatory authority. The Company operates as a trade finance intermediary and arranger, facilitating the connection between corporate clients and licensed banking institutions for the purpose of structuring trade finance instruments.

The Company's intermediary activities do not constitute the provision of regulated investment services, banking services, or payment services as defined under:

• Directive 2014/65/EU on Markets in Financial Instruments (MiFID II);
• Directive 2013/36/EU on Access to the Activity of Credit Institutions (CRD IV);
• Directive (EU) 2015/2366 on Payment Services (PSD2);
• Cyprus Investment Services and Activities and Regulated Markets Law (Law 87(I)/2017).

The Company maintains a comprehensive Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) compliance programme in accordance with:

• EU Directive (EU) 2015/849 (4th AML Directive) as amended by Directive (EU) 2018/843 (5th AML Directive) and Directive (EU) 2018/1673 (6th AML Directive);
• Cyprus Prevention and Suppression of Money Laundering Activities Law (Law 188(I)/2007, as amended);
• Financial Action Task Force (FATF) Recommendations and Guidance on Trade-Based Money Laundering (TBML);
• Wolfsberg Group Trade Finance Principles.

As a Designated Non-Financial Business and Profession (DNFBP) under Cyprus law, the Company is subject to the supervision of the Cyprus Bar Association for AML/CTF compliance purposes (where applicable to legal activities) and maintains direct reporting obligations to the Unit for Combating Money Laundering (MOKAS).

Our AML/CTF programme includes:

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for higher-risk clients;
• Beneficial Ownership identification and verification (UBO register compliance);
• Ongoing transaction monitoring and trade document scrutiny;
• Screening against EU Consolidated Sanctions List, UN Security Council Sanctions, US OFAC SDN List, and UK OFSI Consolidated List;
• Politically Exposed Persons (PEP) screening;
• Staff AML training programme (annual minimum);
• Appointment of a designated Money Laundering Compliance Officer (MLCO).

The Company operates a zero-tolerance policy towards sanctions violations. We do not provide services to, or facilitate transactions involving:

• Any individual or entity listed on the EU Consolidated Sanctions List, UN Security Council Sanctions Lists, US OFAC SDN List, or UK OFSI Consolidated List;
• Any entity owned or controlled (directly or indirectly, 50% or more) by a sanctioned party;
• Any transaction involving goods, services, or territories subject to comprehensive or sectoral sanctions, including but not limited to: Russia, Belarus (financial/trade sanctions), Iran, North Korea, Syria, Cuba, and Crimea/Donetsk/Luhansk regions;
• Any transaction involving dual-use goods, military equipment, or items subject to EU, US, or UK export controls without appropriate licences.

All clients and beneficial owners are screened at onboarding and on an ongoing basis. The Company reserves the right to terminate any engagement immediately and without liability upon identification of a sanctions match or credible sanctions risk.

The Company is registered as a data controller with the Office of the Commissioner for Personal Data Protection of Cyprus in accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and Cyprus Law 125(I)/2018. Our processing activities are conducted in compliance with GDPR principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

For details of our data processing activities, please refer to our Privacy Policy.

The Company is tax resident in Cyprus and subject to Cyprus corporate income tax at the standard rate of 12.5% on net profits. Cyprus has an extensive network of Double Tax Treaties (DTTs) and is a full member of the European Union, subject to EU tax directives including the Anti-Tax Avoidance Directives (ATAD I and II).

The Company complies with the EU Mandatory Disclosure Rules (DAC6) and the OECD Common Reporting Standard (CRS) / Foreign Account Tax Compliance Act (FATCA) where applicable. VAT registration number: CY10412387X.

Nothing on this Website or in any communication from the Company constitutes investment advice, financial advice, legal advice, or any other form of regulated advice. All information is provided for general informational purposes only.

The Company does not assess the suitability or appropriateness of any trade finance instrument for any particular client. Clients are strongly advised to seek independent legal, financial, and tax advice from appropriately qualified professionals before entering into any trade finance transaction.

The Company maintains relationships with a network of correspondent banks and financial institutions across multiple jurisdictions for the purpose of facilitating trade finance instrument issuance. These relationships are subject to the policies, credit criteria, and regulatory requirements of the respective institutions.

The Company does not guarantee the availability of any banking facility, the creditworthiness of any issuing bank, or the acceptance of any instrument by a beneficiary or their bank. All banking relationships are subject to change without notice.

Clients should be aware that correspondent banking relationships may be subject to de-risking by global banks, which can affect the availability and terms of trade finance instruments in certain jurisdictions or sectors.

The Company is acutely aware of the risks of Trade-Based Money Laundering (TBML) as identified by the FATF and the Egmont Group. Our transaction due diligence procedures are specifically designed to detect and prevent TBML typologies, including:

• Over- and under-invoicing of goods and services;
• Multiple invoicing for the same shipment;
• Falsely described goods or services;
• Phantom shipments (no actual movement of goods);
• Misuse of trade finance instruments to move value across borders.

All trade transactions facilitated by the Company are subject to documentary scrutiny, including review of commercial invoices, bills of lading, certificates of origin, and inspection certificates where applicable.

If you have a complaint regarding our services, please submit it in writing to [email protected]. We will acknowledge your complaint within 5 business days and provide a substantive response within 30 calendar days.

If you are not satisfied with our response, you may refer your complaint to the relevant competent authority in your jurisdiction. As the Company is not a regulated financial services firm, consumer financial ombudsman schemes may not apply; however, you retain the right to pursue legal remedies through the courts of Cyprus in accordance with our Terms of Service.

These Regulatory Disclosures are reviewed at least annually and updated as necessary to reflect changes in applicable law, regulatory guidance, or the Company's business activities. The date of the most recent review is indicated below. Material changes will be communicated via a notice on the Website.

Last reviewed: April 2025

For regulatory enquiries, please contact our Compliance Officer at [email protected].