TRANSOIL S.A.R.L (”Client”) is an existing customer of Big Bank LLC (”Bank”).

The Client has a valid

periodic review profile in place, however due to identified serious negative news on one of the Beneficial
Owners, an event driven review is required to be performed.

You are an analyst in the KYC department and the review was assigned to you.

Your Task:

According to the received documentation and based on your assessment:

- Please list all risks associated with the Client and also any mitigating factors you might find,

- Present an ownership structure prepared by yourself showing the UBOs and their relevant ownership
percentage,

- Assess the risk rating of TRANSOIL S.a.r.l and decide whether the Bank should continue or terminate the
business relationship with the Client. Please justify your judgement.

- Additionally, please write an email to your manager asking for either an approval to continue or
terminate the relationship with the Client depending on your decision, and briefly describe your
arguments.

Time:
- 40 minutes to analyse the information and write an email
- up to 20 minutes to present your results

1. Company name: TRANSOIL S.A.R.L

2. Company profile: Transoil S.A.R.L. is an international company incorporates in Luxembourg.
They provide seaborne crude oil and petroleum transportation service.
3. Address: 1 Zone Industriellewolser dudelange, Luxembourg
4. Registration date: 31/03/1998

Board of directors:

 Cipriano Francisco Celestine – Chairman

 Chen Zhijun – CFO
 Rafael van der waals –COO
  Nadja popovic - Execute director
 Alfredo riccardo – Non-executive director
 Francesca Rosso – Non Executive director

Management board:

 Huang Mei
 Juan Jose Gonzaiez
 Bastiaan van den Hagg

Company structure and shares:

76 percentage of TRANSOIL S.A.R.L shares belong to PETROCHEM Group. 25% Cipriano Franccisco Celes,
Aces 30 percentage, and Aces 2 registered in Marshall Island it is offshore country. Bastiaan van den
Hagg, Huang Mei, Juan Jose Gonzaiez who have 40%.40%. And 20% shares respectively

Conclusion:

TRANSOIL S.a.r.l. is an international company incorporated in Luxembourger. They provide seaborne

crude oil and petroleum transportation service. Our fleets include 30 vessels with the majority
comprising of mid- sized carrier. However Juan Jose Gonzaiez he is management board of TRANSOIL
S.a.r.l. He is charged with first-degree and third-degree assault sentence to three years in jail result from
internal screening, from press research Mr. Huang Mei from China and he is billionaire and another red
flag is his sister’s husband is ex- Railway minister of china recently resigned his position. And another red
flag Mr. Cipriano Francisco Celestine he is chairman of TRANSOIL S.a.r.l. he was arrested in Amsterdam
international airport with 500 grams of heroin declined drug trafficking charges from Mexico to
Netherlands. More over the share part of the company 76 % Transoil company’s share belongs to
Petrochem groups and Aces 2 ltd registered in Marshall Island (offshore country). From Mexico takers
loaded with crude petroleum travel to Netherlands. Mexico is high risk country.

During the investigation we have multiple red flags according to the investigations and open source
clearly state that there are multiple suspicious unusual activities is there. Due to identified serious
negative news and received documentation based the case has escalate to L2 level additional
investigation has been required