SANCTIONS POLICY

As a global company based in the United States, we must comply with economic sanctions and trade restrictions, including those implemented by the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury. This means that GBRS Group LLC (GBRS) cannot take part in transactions that involve designated people, places, or items that originate from those places, as determined by agencies like OFAC.

 

Location and Account Information

This sanctions policy applies to you regardless of your location. 

You must provide true and accurate information about yourself and your country of residence when you place an order, create or update your GBRS account or apply on our Dealer Portal. Providing us with false information may result in the termination of your Services.

Our Restrictions

GBRS Group LLC (GBRS) is committed to compliance with all relevant United States (US) laws and regulations, to include economic sanctions. As GBRS’ customer and/or business partner, you are subject to these rules as they apply to your business with GBRS. The United States economic sanctions generally prohibit the following transactions involving:

• Cuba, Iran, North Korea, Syria, Crimea, Donetsk People’s Republic, and the Luhansk People’s Republic. This prohibition also includes individuals and entities who reside or operate in these places.
• Individuals and/or entities who have been designated by OFAC as Specially Designated Nationals, Foreign Sanctions Evaders, or subject to Sectoral Sanctions. This also applies to any entity owned or controlled 50% or more by a sanctioned party, directly or indirectly.

The US Government provides a Consolidated Screening List of individuals and entities sanctioned by the US government. GBRS screens direct to consumer orders against this list, however, GBRS highly recommends our business partners screen the parties to their transactions against this list. Additionally, OFAC publishes a list of their Sanctions Programs which GBRS also highly recommends that you consult.

Other Restrictions

In addition to US sanctions, other countries may have additional trade restrictions and certain items may not be allowed for export or import under international laws. 

GBRS is unable to provide legal advice on specific scenarios you may encounter. Export controls and sanctions are complex and we recommend that you consult with qualified legal counsel for guidance.

Our payment partners may independently monitor financial transactions for sanctions compliance and may block transactions as part of their own compliance programs. GBRS has no authority or control over the independent decision-making of these providers.

Updates

Economic sanctions and trade restrictions are updated frequently and may result in changes in our ability to work with you or there may be additional restrictions on benefits that can be provided.

Additional Resources:

• US Department of the Treasury
• Bureau of Industry and Security at the US Department of Commerce
• US Department of State
• European Commission

GBRS appreciates your support and commitment to compliance.

Updated 3/21/2023