This Acceptable Use Policy ("AUP") governs access to and use of the AquiCargo platform, including the marketplace, Deal Room, request for quotation (RFQ) forms, vendor and buyer dashboards, and all related services (collectively, the "Platform"). By accessing the Platform, you agree to be bound by this AUP in its entirety.

This AUP must be read in conjunction with the Vendor Agreement, Buyer Terms of Service, Privacy Policy, and Anti-Circumvention Policy of AquiCargo.

1. Authorized Purpose

AquiCargo operates exclusively as a U.S.–Cuba agricultural B2B trade corridor, authorized under the Trade Sanctions Reform and Export Enhancement Act of 2000 (22 U.S.C. § 7207) and OFAC Cuba Sanctions Regulations (31 C.F.R. Part 515, Agricultural Export License Exception – TSRA). The Platform may only be used to:

• List, search, and negotiate offers for agricultural and basic consumer goods eligible for legal export from the U.S. to Cuba;
• Submit and respond to Requests for Quotation (RFQs) in compliance with applicable trade laws;
• Complete transactions through the Platform approved payment mechanisms.

Any use outside this purpose is expressly prohibited.

2. Prohibited Uses

2.1 Circumvention Activities

Bypassing the Platform intermediation mechanisms is strictly prohibited. This includes, without limitation:

• Sharing phone numbers, email addresses, instant messaging accounts (WhatsApp, Telegram, Signal, Viber, WeChat), or any other contact data through the Deal Room before the Platform coordination fee has been paid;
• Sharing social media identifiers (Instagram, Facebook, LinkedIn, X/Twitter, or @username-format profiles);
• Posting or transmitting external URLs or web addresses for the purpose of continuing negotiations outside the Platform;
• Disclosing physical addresses, offices, warehouses, or any data that would enable direct contact between parties;
• Completing any transaction related to a negotiation initiated on the Platform without paying the agreed coordination fee, during a period of twenty-four (24) months from the date the first RFQ was submitted.

2.2 Legally Prohibited Activities

Users may not use the Platform to:

• Trade with entities or individuals listed on the OFAC Specially Designated Nationals (SDN) List, the BIS Cuba Restricted List (CRL), or other U.S. sanctions lists;
• Export, re-export, or transfer products or technology in violation of the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), or any other U.S. export control law;
• Represent, act on behalf of, or facilitate transactions that benefit Cuban military, intelligence, or security entities, including without limitation: GAESA, FINCIMEX, MINFAR, MININT, CIMEX, GRUPO DE ADMINISTRACION EMPRESARIAL S.A., or any affiliates or subsidiaries;
• Engage in money laundering, terrorist financing, or other illicit financial activities;
• Submit false or fraudulent KYB declarations, documents, or certifications;
• Export non-agricultural products, dual-use items, luxury goods, or any product category not eligible under TSRA.

2.3 Platform Abuse

The following are also prohibited:

• Creating multiple accounts to evade suspensions, restrictions, or KYB reviews;
• Using automated tools, bots, or scripts to scrape Platform data without prior written authorization;
• Attempting to access other users accounts, dashboards, or data without authorization;
• Posting defamatory, fraudulent, obscene, or third-party intellectual property-infringing content;
• Interfering with the availability, integrity, or performance of the Platform (including DoS/DDoS attacks).

3. Automated Deal Room Monitoring

Messages sent through the Deal Room are automatically analyzed in real time by AquiCargo Anti-Circumvention engine before being delivered to the recipient. This system scans content for:

• Phone numbers (domestic and international formats);
• Email addresses;
• Messaging applications (WhatsApp, wa.me, t.me, Telegram, Signal, Viber, WeChat);
• Social media identifiers (@username, facebook.com, instagram.com, linkedin.com, twitter.com, x.com);
• External URLs and web domains;
• Physical address indicators (street, avenue, blvd, suite, apt, etc.).

Messages containing any of these elements will be automatically blocked and will not be delivered. The sender will receive a block notification along with the cumulative warning count.

Deal Room message content is encrypted with AES-256-GCM in transit and at rest. AquiCargo does not read message content except through the automated analysis described above or when required by a court order or other legal obligation.

The system periodically monitors active deals showing sustained inactivity (no messages for 14 days or more in a negotiation or commission billing status) as an indicator of possible off-platform activity.

4. Identity Anonymization

To protect the integrity of the intermediation process, vendor and buyer identities are anonymized during the negotiation and quotation phases:

• Vendors are identified as U.S. Vendor #AQ-XXXX until the Platform coordination fee has been paid;
• Buyers are identified as Cuba Buyer #AQ-XXXX until the Platform coordination fee has been paid.

Full identity (name, email, company) becomes available to both parties only upon confirmation of coordination fee payment or transaction closing.

5. Strike System & Enforcement

5.1 Warnings for Automated Circumvention Attempts

Each message blocked by the Anti-Circumvention engine generates a warning (strike) recorded on the user profile:

• Warnings 1 and 2: User notification. The event is recorded in the compliance file.
• Warning 3 or more: AquiCargo compliance system is immediately notified. The account is placed under review for possible suspension or termination.

5.2 General Consequences for Violations

Depending on severity and recurrence, violations of this AUP may result in:

• Temporary or permanent account suspension;
• Immediate termination of Platform access without refund;
• Issuance of a circumvention damages invoice equal to 20% of the estimated value of the circumvented transaction, per the Vendor Agreement or Buyer Terms;
• Notification to relevant regulators where the conduct may constitute a violation of U.S. export laws, OFAC sanctions, or BIS regulations;
• Civil or criminal legal action as appropriate.

6. KYB Identity and Compliance Verification

All users must successfully complete the Know Your Business (KYB) process before accessing transactional features. By using the Platform, you authorize AquiCargo to:

• Vendors (U.S.): Verify the Employer Identification Number (EIN) against official IRS format, query the applicable Secretary of State records, run OFAC SDN List searches (fuzzy match ≥ 80%), and request a signed W-9 form (AES-256-CBC encrypted);
• Buyers (Cuba): Verify the Tax Identification Number (NIT), the REEUP/RM number from MINCIN, and MINCEX licenses via OCR document analysis with a confidence threshold ≥ 85%; run OFAC SDN List and BIS Cuba Restricted List (CRL) searches;
• Run periodic compliance screenings (monthly) against updated SDN and CRL lists for active users.

KYB data is processed locally on servers under AquiCargo control. OCR analysis is performed using Tesseract (processed locally). AquiCargo does not share KYB data with third parties except as required by law.

7. OFAC & Cuba Restricted List Screening

The Platform automatically screens against:

• The OFAC Specially Designated Nationals and Blocked Persons List (SDN List), downloaded directly from the U.S. Treasury with a 24-hour cache;
• The Bureau of Industry and Security (BIS) Cuba Restricted List (CRL), which includes entities such as GAESA, FINCIMEX, MINFAR, MININT, CIMEX, Grupo BM, TRD Caribe, Havanatur, ETECSA, and other Cuban military, intelligence, and security entities.

A positive match results in immediate denial of access or account suspension, and notification to AquiCargo compliance system. Screening results are recorded in the compliance audit file.

8. Whistleblower Pathway

Users may report suspicious activity or circumvention attempts through the report form available in their user dashboard. When submitting a report:

• Your identity as a whistleblower will not be disclosed to the reported user at any time;
• You may submit a maximum of 3 reports per 24-hour period;
• Reports are reviewed by AquiCargo compliance system and may result in an investigation, suspension, or closure of the reported account;
• Reports determined to be false or in bad faith will result in a penalty on the reporting user Buyer Trust Score (BTS).

9. Changes to this AUP

AquiCargo reserves the right to modify this AUP at any time. Material modifications will be communicated with at least 14 days notice by email or through a prominent notice on the Platform. Continued use of the Platform after the effective date of any modification constitutes acceptance of the modified AUP.

10. Contact

For questions about this AUP, contact AquiCargo compliance team:

• Email: compliance@aquicargo.org
• Legal address: AlianzaVital LLC d/b/a AquiCargo, Florida, USA