Anti-Circumvention Policy

1. Purpose

AquiCargo operates as a B2B commercial coordination platform connecting U.S. exporters with authorized Cuban buyers under the Trade Sanctions Reform and Export Enhancement Act (TSRA, 22 U.S.C. § 7207). The introduction of commercial parties–seller and buyer–constitutes the core value AquiCargo brings to the market. This Anti-Circumvention Policy protects that value by prohibiting parties introduced through AquiCargo from transacting directly with each other without Platform involvement during the established term.

2. Definition of Circumvention

Circumvention means any of the following acts committed by Vendors, Buyers, or parties associated with use of AquiCargo:

• Directly contacting a counterpart introduced by AquiCargo to negotiate, quote, or close a transaction outside the platform.
• Disclosing contact details (email, phone, WhatsApp, etc.) of buyers or sellers to third parties to replicate the transaction outside AquiCargo.
• Using an intermediary, agent, or affiliated company to do what would constitute a prohibited direct transaction.
• Redirecting orders, payments, or commercial documentation outside AquiCargo once parties have been introduced by the platform.
• Agreeing with an AquiCargo counterpart to pay a commission outside the platform to avoid coordination fees.

3. Term

The anti-circumvention prohibition applies for a period of twenty-four (24) months from the date of the first documented introduction between the parties by AquiCargo, whether through an RFQ, bid proposal, platform communication, or other traceable means.

4. Consequences of Violation

Violation of this Policy may result in: immediate and permanent suspension from the AquiCargo platform; invoice for coordination fees equivalent to 3% of the estimated transaction value; legal action for damages; and reporting to relevant regulatory authorities.

5. Reporting Violations

To report suspected circumvention: compliance@aquicargo.org

AlianzaVital LLC d/b/a AquiCargo · 7901 4th St. N., Suite 300, St. Petersburg, FL 33702 · compliance@aquicargo.org