1. Purpose
This policy sets out Murzo Group's approach to lawful, controlled, and locally compliant activity in the Turks and Caicos Islands.
It is designed to prevent accidental trading, unlicensed activity, unsuitable local representation, regulatory breaches, tax failures, immigration issues, and misuse of the Group's name by third parties operating in or from TCI.
2. Status of the Turks and Caicos Islands
The Group is based in the United Kingdom and may remain subject to UK obligations with overseas effect, including anti-bribery, tax evasion facilitation, sanctions, export controls, modern slavery, data protection, company law, and other mandatory rules where applicable.
TCI is a British Overseas Territory with its own constitution, legislation, licensing system, courts, regulators, public authorities, tax administration, immigration controls, and local business rules. UK law must not be treated as automatically applying in TCI merely because of the constitutional relationship.
UK law may still apply where it expressly extends to TCI, is extended by Order in Council, applies extraterritorially, applies through contract, or applies because the relevant conduct, decision, person, data, product, payment, or company function is connected with the UK.
3. Scope
This policy applies to TCI-facing activity carried out by directors, workers, contractors, consultants, suppliers, agents, resellers, brokers, group companies, joint venture contacts, and any person authorised to act for the Group.
It covers direct operations, property, trading, e-commerce, logistics, import/export activity, tourism or accommodation activity, agriculture, food, live animals, insects, cultural property, high-value goods, regulated services, marketing, recruitment, security, CCTV, Wi-Fi, payments, local partnerships, and premises activity in or from TCI.
4. Compliance Principles
- TCI local law and regulator requirements must be checked before activity starts
- No person may trade, advertise, employ, import, export, occupy premises, collect local revenue, or represent local approval without the correct authority
- UK compliance standards remain a baseline where lawful, but they do not replace TCI requirements
- Local partners must be genuine, properly authorised, and not used to disguise control, ownership, labour, tax, or licensing risk
- Activity must stop or be narrowed where legal authority, permits, licences, insurance, or professional advice are uncertain
5. Legal Gatekeeping Before Activity
Before starting TCI activity, the person responsible must identify the planned activity, the relevant island or location, the contracting party, the proposed legal structure, the local licence or permit position, the tax position, any import/export controls, and whether local legal or professional advice is needed.
The Group must not rely on informal assurances, marketplace settings, social media statements, supplier claims, verbal agency arrangements, property owner assurances, or third-party marketing claims as proof of legal authority.
6. TCI Authority Map
Depending on the activity, relevant TCI authorities or public bodies may include the Inland Revenue Department, Financial Services Commission and Companies Registry, Customs Department, Immigration and Border Services, Labour and Employment Services, Department of Agriculture, Environmental Health, Department of Environment and Coastal Resources, Planning Department, Tourism Regulation Authority or successor bodies, Royal Turks and Caicos Islands Police Force, Financial Intelligence Agency, Attorney General's Chambers, courts, and specialist boards or regulators.
Where a regulator, statutory board, Ministry, or department has jurisdiction, the Group must deal with that authority honestly and only through authorised representatives.
7. Business Licensing
Business carried on in or from within TCI may require a local Business Licence, and more than one licence may be needed where distinct activities are carried on. The licence position must be checked before trading, advertising local services, operating from local premises, or appointing a local representative.
Some activities may be general, reserved, restricted, exclusive, subject to TCI Islander ownership requirements, subject to Cabinet review, affected by moratoria, or subject to separate sector approval. Activity must not be split, renamed, outsourced, or routed through another person to avoid a licence restriction.
8. Corporate Presence and Beneficial Ownership
Where TCI activity requires a local company, registered foreign company, branch, partnership, business name, land holding company, company manager, registered agent, or other structure, the structure must be assessed before commitments are made.
Directors, members, shareholders, beneficial owners, authorised signatories, registered office arrangements, good standing, economic substance, corporate filings, statutory registers, land ownership controls, and sector restrictions must be accurate and defensible.
Nominee, fronting, sham ownership, undisclosed control, false local ownership, or undisclosed beneficial ownership arrangements are prohibited.
9. Immigration, Work and Employment
No worker, consultant, freelancer, contractor, director, secondee, technician, security contact, sales contact, trainer, driver, farm worker, hospitality worker, or temporary visitor may perform work in TCI unless immigration, right to work, work permit, labour clearance, and local employment requirements have been checked.
Local recruitment, advertising, TCI Islander employment priority, work permits, temporary work permits, payroll, national insurance, national health obligations, workplace inspections, employment rights, health and safety, and worker accommodation must be considered where relevant.
A person must not be labelled as a volunteer, visitor, consultant, remote worker, marketplace seller, trainee, family contact, or independent contractor to avoid work permit or employment obligations.
10. Tax, Revenue and Government Fees
TCI tax and revenue obligations may arise from business licences, import duties, customs processing fees, hotel, restaurant and tourism taxes, vehicle hire stamp duty, telecommunications tax, domestic financial services sales tax, insurance premium sales tax, land transfer duties, payroll-related obligations, permits, government fees, penalties, and other activity-specific charges.
The Group must ensure that local taxes, remittances, duties, fees, renewals, and penalties are considered before pricing, contracting, importing, occupying premises, or collecting customer payments in TCI.
11. Customs, Imports, Exports and Regulated Goods
Goods entering or leaving TCI may require customs clearance, declarations, invoices, packing lists, bills of lading or airway bills, permits, certificates, concessions, inspections, or other supporting documents.
Additional care is required for food, agricultural goods, plants, soil, compost, animals, animal products, insects, medicines, pharmaceuticals, chemicals, vehicles, drones, weapons, controlled items, high-value goods, cultural objects, marine products, CITES-sensitive items, and goods intended for resale.
No shipment may be misdescribed, undervalued, split, hand-carried, trans-shipped, or routed through TCI to avoid customs, sanctions, export control, biosecurity, food, wildlife, environmental, or cultural property controls.
12. Sector-Specific Approvals
Some TCI activities require specialist licensing or approval in addition to a general business licence. These may include accommodation, tourism services, liquor, transport, taxis, buses, public service vehicles, real estate brokerage, construction, contractors, financial services, money transmission, insurance, company management, telecommunications, health services, environmental activities, agriculture, food handling, fisheries, public events, security, controlled goods, and premises use.
Where a sector is regulated, the Group must not allow a third party to suggest that ordinary company registration, a UK registration, an online marketplace account, a supplier contract, or a Business Licence alone is enough.
13. Property, Facilities and Land
Property activity in TCI must be checked for land ownership restrictions, lease terms, planning permission, building control, environmental controls, fire and public safety, utilities, insurance, property tax or stamp duty exposure, Crown land issues, landlord consent, title, and local agent authority.
No local office, warehouse, storage site, farm, accommodation unit, retail display, hospitality site, staff housing, collections storage location, or security-sensitive premises may be used until lawful occupation, safety, insurance, and licence implications have been considered.
14. Anti-Bribery, AML, Sanctions and Economic Crime
TCI activity must comply with applicable anti-bribery, anti-corruption, anti-money laundering, counter-terrorist financing, sanctions, source of funds, beneficial ownership, tax evasion facilitation, and fraud prevention requirements.
Facilitation payments, undisclosed commissions, improper gifts, political payments, hidden introducer fees, cash structuring, false invoices, nominee ownership, unauthorised government contacts, and arrangements designed to obtain permits or licences improperly are prohibited.
15. Contracts, Agents and Third Parties
Contracts involving TCI must clearly identify the contracting party, governing law, dispute process, tax responsibility, licence responsibility, delivery terms, insurance, liability, authority to bind, and any local permits required.
Agents, brokers, recruiters, property managers, customs brokers, marketing contacts, tourism operators, fulfilment partners, marketplace sellers, local sponsors, and consultants must not hold themselves out as having authority to bind the Group unless authorised in writing.
To the fullest extent permitted by law, the Group does not accept responsibility for unauthorised local trading, marketing, employment, tax filings, licensing representations, customer promises, product claims, or regulatory breaches by third parties acting outside written authority.
16. Data, Privacy, CCTV, Wi-Fi and Cybersecurity
TCI activity involving personal data, CCTV, staff records, customer records, reservations, Wi-Fi, payments, biometrics, visitor logs, marketing lists, security logs, cloud platforms, or overseas access must be assessed against applicable TCI law, UK law where relevant, contract duties, confidentiality duties, cybersecurity expectations, and supplier controls.
Public-facing notices, customer communications, CCTV signs, staff notices, payment provider terms, Wi-Fi terms, and marketing permissions must not be copied from another jurisdiction without checking that they fit the TCI activity.
17. Incidents, Complaints and Regulator Contact
Suspected unlawful trading, licence breach, customs seizure, work permit issue, tax demand, public authority inquiry, data incident, product safety issue, premises incident, employment complaint, environmental issue, police matter, or reputational risk must be escalated promptly.
Only authorised persons may respond to regulators, sign statements, provide documents, agree settlements, make public statements, admit liability, or instruct local counsel on behalf of the Group.
18. Suspension, Exit and Remediation
Where TCI compliance cannot be confirmed, the Group may pause activity, suspend a local representative, stop marketing, hold shipments, restrict platform listings, cancel events, refuse orders, terminate contracts, close a premises arrangement, or seek local advice before continuing.
Inactive licences, unused registrations, obsolete premises, outdated particulars, dormant partnerships, and abandoned local arrangements should be closed or cancelled where needed to prevent penalties, false authority, or continuing obligations.
19. Practical Compliance Pack
For material TCI activity, a concise compliance pack should identify the activity, entity or contracting party, licence position, authority approvals, tax position, immigration position, premises position, regulator contacts, third-party responsibilities, and escalation route.
The pack should be proportionate to the risk and should not create unnecessary administrative work for low-risk exploratory activity.
20. Responsibility and Review
Directors, managers, project owners, local representatives, and contract owners are responsible for applying this policy to TCI-related activity under their control.
This policy should be reviewed when TCI law, business licensing categories, ownership restrictions, tax rules, immigration rules, sector approvals, customs rules, corporate filing obligations, property rules, or the Group's local activities change.
