AML, KYC, Anti-Bribery & Anti-Corruption, Sanctions
Version: 1.0
|Effective Date: 17-06-2026
|Last Updated: 17-06-2026
This Trade Compliance Policy (the "Policy") sets out the anti-money-laundering (AML), know-your-customer (KYC), anti-bribery and anti-corruption (ABC), and sanctions and export-control standards that apply to HEFGRO ("HEFGRO") and to every buyer, supplier, partner and user of the HEFGRO Platform ("Users"). It forms part of the HEFGRO Terms and Conditions. Breach of this Policy is a material breach of the Terms and may result in immediate suspension, payment freezes, termination and reporting to authorities.
HEFGRO and Users shall comply with all applicable laws, including: the Prevention of Money Laundering Act 2002 (India) and rules; the Foreign Exchange Management Act 1999 (India); the Foreign Trade (Development & Regulation) Act 1992, DGFT regulations and SCOMET export controls (India); the Prevention of Corruption Act 1988 (India); the US Foreign Corrupt Practices Act and OFAC sanctions programs; the US Export Administration Regulations; the UK Bribery Act 2010 and UK (OFSI) sanctions; EU sanctions and Dual-Use Regulation; UN Security Council sanctions; and the AML, ABC and trade-control laws of each jurisdiction in which a User operates or to which goods are shipped.
At onboarding and periodically thereafter, HEFGRO and its licensed payment partners verify: legal entity identity (registration documents, tax registrations such as GSTIN/VAT/TRN, import-export codes); identity of authorised representatives and, where required, beneficial owners (generally those holding 25% or more, or such lower threshold as applicable law or the payment partner requires); bank account ownership for settlements; and licences relevant to the goods traded.
Users and transactions are risk-rated based on factors including jurisdiction, goods category (e.g., dual-use or controlled materials), transaction size and pattern, ownership transparency and adverse media. Enhanced due diligence applies to higher-risk Users, including politically exposed persons, complex ownership structures and higher-risk corridors. Users must promptly provide documents reasonably requested; failure to complete verification results in restricted functionality or suspension.
All payments must flow through the Platform's licensed payment partners; cash transactions and third-party payments (payment by or to a person who is not the contracting party) are prohibited unless expressly approved after due diligence.
HEFGRO and its payment partners monitor transactions for red flags, including: structuring or unusual splitting of payments; pricing materially inconsistent with market value (potential trade-based money laundering); requests to reroute settlements to unrelated accounts or jurisdictions; documentation inconsistencies; and shipments inconsistent with a User's known business.
Suspicious activity may be reported to the competent financial intelligence unit (e.g., FIU-IND) by HEFGRO or its payment partners as required by law. Tipping off is prohibited; HEFGRO will not inform a User that a report has been made where the law so requires.
Records of verification and transactions are retained per the retention schedule in the Privacy Policy and applicable AML law.
HEFGRO maintains a zero-tolerance position on bribery and corruption. No User, and no director, employee or agent of HEFGRO, may offer, promise, give, solicit or accept any bribe, kickback, facilitation payment or other improper advantage — directly or through intermediaries — to or from any public official or private party, to obtain business or any improper advantage in connection with the Platform.
Gifts and hospitality connected to Platform business must be reasonable, transparent, lawful and never intended to improperly influence a decision.
Users must maintain accurate books and records of Platform transactions and must not create false or misleading documentation (including invoices, certificates and customs declarations).
Suspected corruption may be reported confidentially to compliance@hefgro.com; HEFGRO prohibits retaliation against good-faith reporters.
Screening: Users, beneficial owners, counterparties, vessels and destinations are screened against applicable lists, including UN consolidated lists, US OFAC SDN and sectoral lists, EU consolidated list, UK OFSI list and Indian denial lists. Screening occurs at onboarding, periodically, and at transaction milestones.
Prohibitions: Users must not engage in any Platform transaction that involves: a sanctioned person or entity, or an entity owned or controlled by one; a comprehensively embargoed territory; prohibited end-uses (including weapons proliferation); or goods requiring an export licence (e.g., SCOMET or dual-use items) without that licence being obtained and evidenced.
No diversion: Buyers warrant goods will not be re-exported or diverted contrary to applicable export-control or sanctions laws.
HEFGRO's authority: HEFGRO may immediately and without prior notice decline, suspend, freeze or unwind any transaction, freeze pending settlements, and suspend or terminate any User, where it reasonably believes this Policy or applicable trade-control law is or may be breached. HEFGRO bears no liability for losses arising from such compliance actions taken in good faith.
Users must not list, supply or document counterfeit, adulterated, stolen or misdeclared goods. Submission of forged certificates, inspection reports, transport documents or customs paperwork is treated as fraud: HEFGRO will suspend immediately, freeze related settlements, cooperate with Buyers, insurers and law enforcement, and may permanently ban the User and affiliated entities.
HEFGRO's [Compliance Officer / designated senior manager] owns this Policy, oversees screening tools and escalations, approves enhanced-due-diligence decisions, and reports to management. Personnel receive periodic training. This Policy is reviewed at least annually and upon material regulatory change.
Compliance concerns, sanctions questions and whistleblowing reports: hello@hefgro.com