1. Purpose
This policy sets out the Group's approach to sanctions, export controls, trade restrictions and restricted-party screening for activity in or connected with the Turks and Caicos Islands.
The purpose is to prevent unlawful transactions, shipments, payments, property dealings, services, technology transfers, customer relationships, supplier relationships, platform activity and third-party arrangements involving sanctioned persons, restricted goods, prohibited destinations, restricted end uses or controlled technology.
The Group may refuse, delay, freeze, suspend, cancel, report or terminate any activity where sanctions, export-control or restricted-party risk cannot be cleared to an acceptable standard.
2. Scope
This policy applies to Murzo Group Ltd and all subsidiaries, controlled entities, divisions, brands, branches, projects, premises, accounts, platforms, assets and operations conducting business in or from the Turks and Caicos Islands.
It applies to directors, officers, employees, temporary personnel, contractors, consultants, agents, brokers, customs brokers, freight forwarders, property agents, suppliers, distributors, marketplace contacts, fulfilment partners, technology providers, local representatives and any person acting for or on behalf of the Group.
It covers goods, services, payments, refunds, commissions, imports, exports, re-exports, transhipments, temporary movements, software, technology, AI systems, technical data, design files, repairs, samples, customer support, property, rentals, leases, high-value goods, cultural objects, security-related items, dual-use items, controlled items and online marketplace activity.
3. TCI Sanctions Context
The Governor is the competent authority in TCI for the implementation of targeted financial sanctions, subject to any lawful delegation of functions. Sanctions in TCI flow from United Nations and United Kingdom measures and may be given effect in TCI through Orders in Council or other legislation extended to the Overseas Territories.
TCI sanctions orders and notices may be published through the TCI Gazette, the Attorney General's Chambers, the Financial Services Commission and other official routes. The Group must not rely on old local copies, informal lists, news articles or supplier assurances where current official information is needed.
It is a criminal offence to breach applicable sanctions requirements. The Group must treat sanctions compliance as a stop-first control, not as a paperwork exercise after a transaction has already moved.
4. Murzo Group's Wider UK Obligations
Murzo Group Ltd is incorporated in the United Kingdom. UK sanctions may apply to UK companies and UK persons outside the UK, including where activity is carried on in TCI, through TCI partners, through overseas subsidiaries, through digital services or through third-party fulfilment arrangements.
UK sanctions may include financial sanctions, director disqualification sanctions, trade sanctions, arms embargoes, transport sanctions, immigration sanctions and restrictions on services, technology, brokering, finance, insurance or economic resources.
Where TCI rules, UK rules, UN measures, bank rules, platform rules, insurer requirements or contract duties overlap, the Group should apply the most restrictive lawful requirement unless legal advice confirms another approach.
5. Restricted Parties
Restricted parties include designated persons, specified ships, sanctioned entities, sanctioned public bodies, entities owned or controlled by sanctioned persons, blocked or frozen asset holders, prohibited end users, sanctioned vessels or aircraft, sanctioned banks, sanctioned insurers, restricted brokers, sanctioned government bodies and persons acting on behalf of any of them.
A counterparty may be restricted even if its own name does not appear on a list, where ownership, control, agency, nominee arrangements, beneficial ownership, management control, voting rights, contractual control or practical influence connects it to a designated person or restricted entity.
6. Screening Triggers
Restricted-party screening should be considered before onboarding customers, suppliers, agents, brokers, landlords, tenants, buyers, sellers, investors, distributors, fulfilment partners, customs brokers, freight forwarders, payment providers, marketplace accounts, high-value goods counterparties, property counterparties and any party connected with higher-risk jurisdictions or restricted goods.
Screening must be refreshed where names change, beneficial ownership changes, bank details change, shipping routes change, destination changes, end use changes, licence status changes, sanctions lists change, payment routes change or new red flags arise.
7. Countries, Regions and Routes
Sanctions and export-control risk may arise from the country of origin, destination, transit route, ownership, vessel, aircraft, port, bank, insurer, platform, customer location, end user, end use or party providing related services.
TCI must not be used as a routing, storage, fulfilment, payment, property, brokerage, marketplace or transhipment point to avoid UK, TCI, UN or other applicable restrictions.
8. Goods, Software, Technology and Services
Additional review is required before handling defence goods, firearms, explosives, ammunition, security equipment, drones, sensors, robotics, AI systems, cybersecurity tools, encryption, surveillance equipment, dual-use items, chemicals, laboratory equipment, vehicles, marine equipment, aircraft parts, electronics, telecoms equipment, energy equipment, luxury goods, cultural objects, high-value goods, precious metals, stones, art, antiquities, food, agricultural goods, animals, insects or biological materials.
Export controls and trade sanctions may apply to physical goods, intangible transfers, cloud access, source code, technical assistance, design files, drawings, training, repairs, maintenance, brokering, financing, insurance, logistics, marketing support and other services connected with controlled goods or technology.
9. End Use and End User Controls
The Group must assess end use and end user risk before supplying goods, services, technology, software or technical assistance where there is a risk of military use, internal repression, terrorism, proliferation, sanctions evasion, cyber misuse, surveillance misuse, human rights abuse, weapons development, forced labour, cultural property trafficking, wildlife crime, environmental harm or unlawful re-export.
Customers, agents, brokers, distributors and platforms must not conceal the true end user, destination, ownership, funding source, route, cargo contents, technical capability or onward transfer plan.
10. Customs, Import and Export Controls
All TCI import, export, re-export and transhipment activity must be assessed for customs, licensing, sanctions, export-control, product safety, biosecurity, cultural property, wildlife, firearms, food, chemical and environmental restrictions before goods move.
Goods must not be misdescribed, undervalued, split, repacked, relabelled, routed, hand-carried, gifted, sampled, repaired or returned in a way intended to avoid sanctions, export controls, customs duties, inspection, permits or lawful authority review.
11. Payments, Refunds and Economic Resources
Financial sanctions may prohibit making funds or economic resources available directly or indirectly to, for the benefit of, or at the direction of a restricted party. This can include payments, refunds, credits, deposits, commissions, rent, property services, free goods, discounts, cryptoassets, vouchers, insurance, finance, transport, storage, technical assistance and use of assets.
Funds or assets connected with a sanctions concern may need to be frozen, held, rejected, reversed, blocked, reported or handled only under a valid licence or competent authority instruction.
12. Property, Land and Facilities
TCI property activity requires sanctions and restricted-party review where relevant. This includes acquisitions, leases, rentals, facilities management, construction, land holding companies, beneficial ownership, landlords, tenants, buyers, sellers, agents, developers, lenders, insurers, service providers and persons funding the transaction.
The Group must not make property, accommodation, facilities, security services, utilities, rent concessions, asset management or other economic resources available to a restricted party unless lawful authority has been confirmed.
13. High-Value Goods and Cultural Objects
High-value goods, luxury goods, fashion items, jewellery, precious metals, art, antiquities, archaeological material, cultural objects, sacred objects and collections can create sanctions, AML, customs, provenance and export-control risk.
The Group may refuse to buy, sell, store, ship, market, value, insure, finance, display, broker or return goods where ownership, source of funds, destination, sanctions status, provenance, export licence or lawful title cannot be cleared.
14. Digital Transfers, AI and Technical Data
Export controls and sanctions can apply to technology and information, not only physical goods. The Group must assess controlled transfers before giving access to source code, models, algorithms, datasets, technical drawings, security tools, design files, passwords, admin access, cloud repositories, AI systems, robotics data or specialist training.
Remote access from or into TCI, cloud sharing, email attachments, file transfer links, video calls, technical support sessions and platform permissions may all create transfer risk where controlled technology or restricted parties are involved.
15. Licences, Exceptions and Authorisations
A sanctions licence, export licence, general licence, exception or authorisation may allow activity that would otherwise be restricted, but it must be checked against the exact regime, parties, goods, services, destination, value, timing and conditions.
No person may rely on a licence, exception, government permission, customs release, platform approval, bank processing or broker statement unless the responsible authorised person has confirmed that it applies to the specific activity.
Where both TCI and UK permissions may be needed, one authorisation must not be treated as satisfying the other unless legal advice or competent authority guidance confirms that position.
16. Third Parties, Brokers and Platforms
Agents, distributors, customs brokers, freight forwarders, property agents, marketplace operators, fulfilment partners, payment processors, advisers, contractors and local representatives must not be used to avoid sanctions, export controls, customs controls, bank controls, source-of-funds checks or restricted-party screening.
Third parties must not change destination, route, consignee, end user, commodity description, product description, invoice value, payment route or ownership information without approval.
17. Red Flags
Red flags include reluctance to identify beneficial owners, unusual routing, sudden destination changes, vague end-use explanations, cash or crypto pressure, shell companies, offshore chains, urgent shipment pressure, requests to remove names from invoices, mismatched customer and payer details, inconsistent addresses, sanctioned-country links, high-risk ports, unusual property discounts, requests to split shipments and refusal to provide source-of-funds information.
Other red flags include military or security end-use clues, dual-use technical requests, requests for excessive confidentiality, unfamiliar intermediaries, recently incorporated buyers, vessel or aircraft name changes, sanctioned bank involvement, unsupported cultural property provenance, and statements that another party will "handle the paperwork".
18. Screening Results and False Positives
A possible match must be paused and reviewed before the transaction proceeds. False positives should be resolved using proportionate identifiers such as full name, aliases, date of birth, place of birth, registration number, address, beneficial ownership, vessel details, aircraft details, passport information, nationality, ownership structure or other lawful identifiers.
No person may ignore or override a match because the customer is commercially important, a shipment is urgent, a public official is involved, a supplier insists, a platform has accepted the listing or funds have already been received.
19. Stop, Freeze, Reject or Escalate
The Group may stop shipments, freeze funds, block access, reject payments, hold refunds, refuse orders, suspend customer support, disable accounts, hold goods, cancel listings, halt property activity, pause contracts, delay delivery, refuse technical support or terminate arrangements where sanctions or export-control risk is unresolved.
No liability should arise from a lawful and proportionate refusal, delay, hold, suspension or termination connected with sanctions, export controls, restricted parties, licensing uncertainty, bank instructions, platform rules, customs detention or competent authority requirements.
20. Reporting and Authority Contact
Suspected sanctions breaches, frozen assets, attempted circumvention, suspicious parties, restricted goods, prohibited services, licence breaches, customs evasion, trade-sanctions concerns or restricted-party matches must be escalated promptly through the internal route.
Where required, the matter may need to be reported to the competent TCI authority, the Financial Services Commission, the Attorney General's Chambers, law enforcement, customs, banks, insurers, platforms, OFSI, OTSI, HMRC, ECJU or another competent authority depending on the conduct and legal nexus.
Employees and representatives must not tip off a counterparty, destroy evidence, alter documents, release funds, ship goods, provide services or give technical access while an unresolved sanctions concern is under review.
21. Training and Practical Controls
People involved in TCI sales, procurement, property, finance, customs, shipping, high-value goods, cultural objects, technology, security, controlled items, marketplace activity or customer onboarding should understand the sanctions and export-control red flags relevant to their role.
Practical controls may include screening, approval gates, supplier checks, end-use questions, destination checks, shipping holds, payment holds, contract clauses, platform restrictions, customs broker instructions and escalation before money, goods or technology move.
22. Evidence and Retention
Sanctions and export-control evidence should be limited to what is reasonably needed for legal compliance, authority response, bank review, insurer review, dispute handling, licence conditions, customs issues, audits or legal hold.
Evidence may include screening outputs, licences, legal advice, end-use statements, customs documents, invoices, shipping papers, payment holds, correspondence, ownership checks, source-of-funds information and authority communications where relevant.
23. Accountability
Failure to comply with this policy may result in refusal of the transaction, removal of authority, system access restriction, contract remedies, disciplinary action, regulator notification, law enforcement referral, insurer notification, civil recovery or other lawful action.
Deliberate circumvention, concealment, false declarations, unauthorised shipments, prohibited payments, sanctions evasion, tipping off, destruction of evidence or misuse of TCI as a routing point may be treated as serious misconduct or contractual breach.
24. Relationship With Other Policies
This policy should be read with the TCI Legal and Regulatory Compliance Policy, TCI Business Licensing and Corporate Compliance Procedure, TCI Financial Controls, Fraud and Cash-Handling Policy, TCI Anti-Bribery, Gifts and Hospitality Policy, TCI Records Retention and Legal Hold Schedule, Customs Import/Export Policy, Export Controls and Sanctions Compliance Policy, Importer of Record, Exporter of Record and Customs Broker Policy, Incoterms, Delivery, Shipping and Risk Policy, Defence and Security Compliance Policy, Weapons, Firearms, Explosives and Controlled Items Policy, High-Value Goods, Anti-Money Laundering and Source of Funds Policy, Cultural Property and Provenance Policy, Responsible Materials Policy, Cybersecurity and Data Breach Policy, AI Governance and EU AI Act Readiness Policy, Supplier Approval, Procurement and Due Diligence Policy, and Insurance and Liability Disclosure Statement.
