Sanctions and Export Compliance Policy

1. Our commitment

Fromerica LLC will not knowingly provide its services to, or facilitate transactions with, countries and regions under comprehensive U.S. sanctions or restricted parties, and will not comply with, or pass on requests to comply with, unsanctioned foreign boycotts. Compliance takes priority over revenue.

We maintain a written Sanctions and Export Compliance Program, approved by our Manager, who acts as Compliance Officer. It follows the U.S. Treasury's A Framework for OFAC Compliance Commitments (management commitment, risk assessment, internal controls, testing and auditing, and training) and the U.S. Department of Commerce's Export Compliance Guidelines. These are voluntary frameworks; neither agency certifies or endorses private companies.

2. What Fromerica does and does not do

Fromerica is an online marketplace and set of export tools. It does not buy, sell, ship or export goods, and does not handle payments between users. Exporters listed on the Platform remain responsible for their own export classifications, licenses and filings.

3. Controls built into the Platform

• Sanctioned locations: accounts cannot be opened for, and requests for quote cannot be sent to, locations under comprehensive U.S. sanctions or export controls (currently Cuba, Iran, North Korea, Syria and the Crimea, Donetsk and Luhansk regions of Ukraine). Exporters cannot list these locations as export markets.
• Restricted parties: business and contact names are screened at registration against the U.S. government's Consolidated Screening List (including OFAC's SDN list and BIS's Entity List), updated daily; possible matches are held or reviewed by our Compliance Officer.
• Location of the connection: at registration we check the approximate country of the connection; a registration from a sanctioned country or region is reviewed by our Compliance Officer before the account is relied on.
• High-risk destinations: requests for quote to Russia, Belarus and Venezuela carry an export-control warning for U.S. suppliers and are reviewed.
• Antiboycott: requests for quote and messages that ask for compliance with an unsanctioned foreign boycott are not published or delivered (15 CFR part 760).
• Terms of Use: every user agrees to comply with U.S. export control, sanctions, restricted-party and antiboycott laws; we may refuse or close accounts for compliance reasons.

4. Records, training and review

Every screening decision is recorded and kept for ten years, as required by OFAC (31 CFR 501.601). Our Compliance Officer completes U.S. government sanctions and export control training at least once a year, and we review and test the Program at least once a year and whenever the rules or our services change.

5. Anti-money laundering, anti-fraud and anti-corruption

Fromerica is not a bank or money transmitter: it does not hold or move money between users, so it is not a financial institution under the U.S. Bank Secrecy Act. Payments for our own subscriptions are processed by Stripe, a regulated payment provider. As a U.S. company formed in Florida, Fromerica LLC is exempt from beneficial ownership reporting to FinCEN under its final rule effective August 14, 2026.

Because trade platforms can be misused for scams and trade-based money laundering, we voluntarily:

• check messages between users for common warning signs described by FinCEN and the FTC (overpayments, third-party payments, changed bank details, cryptocurrency or gift-card payments, advance fees), warn the recipient and review the case;
• include a safety notice in every buyer message we forward, and publish a guide on how to spot trade scams;
• prohibit in our Terms any use of the Platform for fraud, money laundering or bribery, and suspend accounts involved;
• remind suppliers bidding on government tenders that the U.S. Foreign Corrupt Practices Act forbids offering anything of value to foreign officials.

6. Report a concern

If you believe a listing, request or user may involve a sanctioned party, a restricted destination, a boycott request, fraud or money laundering, write to info@fromerica.com with the subject "Compliance". We review every report. For questions about your own exports, see the Bureau of Industry and Security, OFAC, or your local U.S. Commercial Service office.

This page is a summary of our internal program and is not legal advice.