AquiCargo Regulatory Compliance Framework
4 independent verification layers. Every company on AquiCargo undergoes OFAC screening, KYB, CRL, and TSRA certification before operating. No exceptions.
Compliance system
4 Independent Verification Layers
No company buys or sells on AquiCargo without passing through all four layers. The system is automatic, continuous, and audited.
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Layer 1 – KYB (Know Your Business)
Business identity verification: incorporation documents, NIT/EIN, ownership chain, and authorized representative. U.S. suppliers submit a signed W-9. Cuban buyers submit an 11-digit NIT, REEUP or Certificate of Incorporation, and MINCEX/MINCIN import authorization according to entity type (MSME, cooperative, state-owned, NGO).
⚖️ Framework: FinCEN / BSA AML
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Layer 2 – OFAC SDN Screening
Every company and its principals are verified against the U.S. Treasury's SDN (Specially Designated Nationals) list – the list of persons and entities with whom U.S. citizens are prohibited from doing business. Screening is executed upon registration, at each KYB, and periodically on an automatic basis. No entity on the SDN list can operate on AquiCargo.
⚖️ Framework: OFAC 31 C.F.R. §501
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Layer 3 – CRL Screening
All Cuban buyers are verified against the U.S. State Department's Cuba Restricted List (CRL) – a list of Cuban government entities with which trade is prohibited or restricted under CACR regulations. Re-screening is monthly and automatic for all active buyers registered on the platform.
⚖️ Framework: CACR 31 C.F.R. §515.209
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Layer 4 – TSRA Self-Certification
All suppliers sign a TSRA self-certification under penalty of federal law, declaring that the exported products qualify under the Trade Sanctions Reform and Export Enhancement Act (22 U.S.C. §7207). The signature includes verbatim legal text, is recorded with an immutable timestamp, and automatically generates the documentation checklist for each transaction.
⚖️ Framework: TSRA 22 U.S.C. §7207 · BIS EAR 15 C.F.R. §730
Compliance infrastructure
Designed to Demonstrate Due Diligence
100% Self-Hosted
OFAC, CRL, and KYB screening running on our own infrastructure. No third parties that fail, no variable costs, no external dependencies.
Immutable Audit
Every screening result, every KYB signature, every transaction is recorded in aqc_compliance_audit with a timestamp and cannot be retroactively modified.
Continuous Re-screening
It's not just upon registration. OFAC SDN is updated from the U.S. Treasury every 24 hours. CRL is re-verified monthly for all active buyers.
Encrypted Documents
All KYB documents (W-9, incorporation, ID, REEUP) are stored with AES-256-CBC encryption with a unique key per file. Every access is logged.
Automatic Documentation
Every closed transaction generates a proforma invoice, TSRA checklist, and certification with complete traceability – ready for regulatory audit without manual work.
Pre-Payment Anonymization
Before the coordination fee is paid, buyers and sellers only see each other as "U.S. Supplier #AQ-XXXX" and "Cuba Buyer #AQ-XXXX." Native anti-circumvention.
Compliance badges
What You'll See on Every Supplier Profile
Badges are not decorative – each one reflects a real, audited, and continuous verification.
[aqc_compliance_badges style="grid" theme="light"]Click on any badge to view the applicable legal framework.
What Laws Apply to U.S. – Cuba Trade?
AquiCargo operates exclusively under the TSRA legal corridor, the only federal channel that has authorized commercial exports of food, hygiene, and medicine from the U.S. to Cuba since 2000.
?? TSRA – 22 U.S.C. §7207
Trade Sanctions Reform and Export Enhancement Act (2000). Authorizes exports of agricultural, food, and medical products from the U.S. to Cuba. Requires cash-in-advance payment or third-country financial institution financing; prohibits U.S. government or bank financing.
? OFAC – 31 C.F.R. §515
Cuban Assets Control Regulations. Controls all financial transactions with Cuba. Exports authorized under TSRA have a specific general license – AquiCargo verifies that each transaction qualifies.
? BIS / EAR – 15 C.F.R. §730
Export Administration Regulations of the Bureau of Industry and Security. Regulates the export of dual-use goods. Food and medicine under TSRA are generally exempt, but require correct EAR classification.
? FinCEN / BSA AML
Bank Secrecy Act. Requires business identity due diligence (KYB/KYC) in international commercial transactions. AquiCargo applies structured KYB to demonstrate AML compliance for any regulatory review.
? CACR – 31 C.F.R. §515.209
Cuba Restricted List of the State Department. Lists Cuban government entities with which trade is restricted. AquiCargo re-verifies all active buyers against this list monthly.
?️ IEEPA – 50 U.S.C. §1701
International Emergency Economic Powers Act. Legal basis for the president's sanction powers. OFAC sanctions against Cuba derive in part from this statute. Reinforces why SDN screening is not optional.
Frequently Asked Questions about Compliance
Why does AquiCargo verify buyers AND sellers?
Because OFAC and the TSRA framework require it on both sides. A U.S. supplier selling to an entity on the CRL is in violation of CACR regulations, regardless of good faith. AquiCargo is responsible as a platform for facilitating only transactions where both parties comply – that's why we apply bilateral screening.
Is trade in food and medicine with Cuba legal?
Yes, under the TSRA corridor. The Trade Sanctions Reform and Export Enhancement Act (2000) explicitly authorized commercial exports of food, agricultural products, and medical supplies from the U.S. to Cuba. AquiCargo operates exclusively within this legal corridor and all transactions are documented to comply with TSRA general license requirements.
What happens if a company appears on the SDN list after registering?
Automatic re-screening detects the match in the next cycle (maximum 24 hours for OFAC SDN, 30 days for CRL). The account is suspended immediately and automatically, all active transactions are frozen, and AquiCargo's compliance system receives an alert to review the case. Access is not restored until the situation is resolved with documentation.
How are my verification documents protected?
All documents (W-9, incorporation, ID, REEUP, MINCEX authorization) are stored with AES-256-CBC encryption with a unique IV per file. The storage directory is protected by .htaccess (direct access blocked). Every query or download is logged in the audit log. Only AquiCargo's compliance system can access them – they are not visible to buyers or other suppliers.
What is TSRA self-certification and what does signing it entail?
It is a legal declaration that the supplier signs upon registration, affirming that the products they export qualify under TSRA (food, hygiene, medicine) and that the transaction complies with all applicable regulatory requirements. The signature is made under penalty of federal law – a false statement is a federal criminal violation. The legal text is verbatim (cannot be modified) and is recorded with an immutable timestamp in AquiCargo's audit system.
How can I demonstrate compliance to my bank or legal advisor?
AquiCargo automatically generates the file for each transaction: proforma invoice, TSRA checklist, certification record, and complete process traceability. This package is designed to be presented directly to correspondent banks, legal advisors, or regulatory auditors. The immutable audit system ensures that records have not been altered.
Ready to Operate with Legal Certainty?
Join the only B2B platform designed from the ground up for the U.S. – Cuba TSRA corridor – with compliance integrated at every step.
Operated by
AlianzaVital LLC d/b/a AquiCargo · St. Petersburg, FL · aquicargo.org
This page is informational and does not constitute legal advice. For regulatory compliance inquiries, consult an attorney specializing in trade with Cuba.