Compliance Policy Manual
Know Your Customer (KYC), Export Compliance (OFAC/EAR), Trade Compliance & Restricted Countries Policy
Document Number: JLT COMPLIANCE INFO DATA
Version: 1.0
Effective Date: July 2026
Approved By: Chief Executive Officer
Applies To: All employees, contractors, officers, agents, logistics partners, suppliers, purchasing personnel, finance personnel, export managers, and third-party representatives.
1. Purpose
Jay Logistics & Trade LLC (“JLT”) is committed to conducting business with integrity while complying with all applicable United States and international laws governing international trade, anti-money laundering (AML), export controls, economic sanctions, customer due diligence, and financial crime prevention.
This policy establishes minimum compliance standards for:
- Customer verification (Know Your Customer)
- Supplier verification
- International trade compliance
- Export control compliance
- Economic sanctions compliance
- Restricted jurisdictions
- Payment risk management
- Shipping compliance
- Recordkeeping
- Employee responsibilities
2. Scope
This policy applies to every commercial transaction involving:
- Wholesale transactions
- International exports
- Domestic shipments
- Freight forwarding
- Procurement
- Product sourcing
- Engineering services
- Manufacturing services
- E-commerce sales
- Online payments
- Stripe payment processing
- Bank wire transfers
- Letters of Credit
- Third-party logistics services
3. Know Your Customer (KYC) Policy
Objective
JLT will make reasonable efforts to understand with whom it conducts business and reduce the risk of fraud, money laundering, sanctions violations, or other unlawful activity.
Customer Information Collection
For commercial transactions, JLT may collect:
- Customer legal name
- Company name
- Business registration
- Billing address
- Shipping address
- Telephone number
- Email address
- Tax identification number (where appropriate)
- Payment information
- Authorized purchaser information
Business Verification
For business customers, JLT may verify:
- Company registration
- Website legitimacy
- Corporate email domain
- Business location
- Commercial references when appropriate
- Import/export licensing where required
Risk-Based Customer Review
Transactions may receive additional review when they involve:
- High-value purchases
- International wire transfers
- Freight forwarding requests
- Unusual shipping routes
- Multiple payment methods
- Requests to change delivery locations
- Requests to conceal ownership
- High-risk jurisdictions
Management may request additional documentation before approving these transactions.
4. Supplier Due Diligence
Before engaging new suppliers, purchasing personnel should perform reasonable due diligence including:
- Business registration review
- Factory verification where practical
- Product capability review
- Banking verification
- Shipping capability review
- Commercial references where available
- Export documentation review
Suppliers that present elevated legal or compliance risk may be rejected.
5. Export Compliance Policy
JLT complies with applicable U.S. export control laws including:
- Export Administration Regulations (EAR)
- Office of Foreign Assets Control (OFAC)
- U.S. Customs regulations
- Applicable export licensing requirements
Where applicable, international transactions are reviewed before shipment.
Export Documentation
When required, export documentation may include:
- Commercial Invoice
- Packing List
- Bill of Lading
- Air Waybill
- Certificate of Origin
- Export Declaration
- Import permits where required
- Purchase Order
- Sales Contract
Product Classification
Products may be reviewed to determine:
- Export control classification
- Country of origin
- Applicable licensing requirements
- Destination restrictions
If licensing is required, shipment shall not proceed until all required approvals are obtained.
6. OFAC & Sanctions Compliance
JLT is committed to complying with applicable sanctions laws.
Where appropriate, customers, suppliers, logistics providers, financial institutions, and counterparties may be reviewed against applicable sanctions lists including:
- OFAC Specially Designated Nationals (SDN)
- OFAC Consolidated Lists
- United Nations Sanctions List
- United Kingdom HM Treasury Sanctions List
- European Union Consolidated Sanctions List
- Other applicable government sanctions lists
Potential sanctions matches shall be reviewed before business proceeds.
7. Restricted Countries Policy
JLT will not knowingly facilitate transactions involving jurisdictions prohibited under applicable sanctions laws or Stripe requirements.
These currently include:
- Cuba
- Iran
- North Korea
- Syria
- Crimea Region
- Donetsk Region
- Luhansk Region
The company will monitor regulatory changes and update this list as required.
8. Shipping Compliance
Prior to shipment, personnel should verify:
- Customer name
- Delivery address
- Shipping documentation
- Freight routing
- Country of destination
- Product description
- Commercial invoice accuracy
Where practical, Bills of Lading and routing information should be reviewed to identify unusual or prohibited shipment paths.
9. Payment Compliance
Payments may be reviewed for unusual activity including:
- Multiple payment attempts
- Third-party payments
- High-value purchases inconsistent with customer profile
- Requests to split transactions
- Refund abuse
- Chargeback fraud
- Payment identity inconsistencies
Transactions presenting elevated risk may be delayed pending additional review.
10. Fraud Prevention
JLT seeks to reduce fraud through reasonable commercial controls, which may include:
- Billing and shipping address comparison
- Verification of customer contact information
- Review of unusual purchasing patterns
- Manual review of flagged orders
- Verification of high-value transactions before shipment
11. Third-Party Logistics Compliance
When using freight forwarders, carriers, customs brokers, or logistics providers, JLT expects partners to comply with applicable laws.
The company may review:
- Shipping instructions
- Bills of Lading
- Freight routing
- Customs documentation
- Delivery destinations
12. Record Retention
Compliance records may include:
- Customer records
- Supplier records
- Payment records
- Shipping records
- Commercial invoices
- Bills of Lading
- Purchase Orders
- Compliance review documentation
Records will be maintained in accordance with applicable legal and business requirements.
13. Employee Responsibilities
Employees shall:
- Follow this policy.
- Report suspected violations.
- Escalate unusual transactions.
- Cooperate with compliance reviews.
- Complete any required compliance training.
Employees may not knowingly approve transactions that violate applicable law.
14. Reporting Concerns
Employees should promptly report concerns involving:
- Suspected fraud
- Money laundering
- Sanctions concerns
- Export control issues
- Falsified documentation
- Suspicious payments
- Suspicious shipping requests
Reports should be made to company management immediately.
15. Policy Violations
Violations of this policy may result in:
- Transaction rejection
- Suspension of business relationships
- Internal disciplinary action
- Referral to legal counsel where appropriate
- Notification to relevant authorities if required by law
16. Annual Review
Management will periodically review this policy to ensure it remains consistent with:
- Applicable laws
- Regulatory guidance
- Company operations
- Payment processor requirements
- International trade regulations
17. Management Statement
Jay Logistics & Trade LLC is committed to maintaining a responsible and compliant international business. The Company expects all personnel, contractors, and representatives to conduct business ethically, comply with applicable laws, support financial crime prevention efforts, and cooperate fully with customer due diligence, export compliance, and sanctions compliance procedures.
This policy is intended to promote lawful trade, protect customers and business partners, and support the Company’s commitment to responsible international commerce