Sanctions & Trade Compliance Policy
Gloseg B2B Limited Effective Date: August 16, 2026 Version: 1.0
Definitions
"Gloseg" means Gloseg B2B Limited, headquartered in Accra, Ghana, with registrations in Nigeria and the United Kingdom.
"Sanctions Regime" means restrictive measures imposed by the United Nations, the European Union, the United Kingdom, the United States (including OFAC), and the domestic law of a Seller's or Buyer's jurisdiction.
"Restricted Party" means a person, entity, or vessel listed on a consolidated sanctions or watch list maintained under any applicable Sanctions Regime.
"Restricted Jurisdiction" means a country or territory subject to comprehensive or sectoral sanctions under any applicable Sanctions Regime.
"Dual-Use Goods" means items with both civilian and military or proliferation-sensitive applications, controlled under export control lists.
"Controlled Goods" means goods, technology, or software subject to an export licence, permit, or authorisation requirement under applicable law.
"Screening" means the automated and manual process of checking Organizations, transaction parties, and payment instructions against Sanctions Regime lists.
"Screening Hold" means the suspension of a payment, Escrow release, or Payout pending resolution of a Screening match.
"End-Use Assurance" means a statement by a Buyer as to the final use and end user of Controlled Goods.
"Diversion" means the unauthorised redirection of goods to a destination, end use, or end user other than that declared.
1. Purpose and scope
1.1 Purpose
1.1.1 Objective
- This Policy sets out Gloseg's approach to sanctions, export control, and trade compliance risk across its cross-border B2B marketplace, and the obligations placed on Organizations trading on the Platform.
1.2 Scope
1.2.1 Application
- This Policy applies to every Seller Organization, established in one of the 54 African countries, and every Buyer Organization worldwide, and to every transaction, RFQ, Order, and payment processed through the Platform.
2. Applicable regimes
2.1 Regimes considered
2.1.1 List
- Gloseg has regard to United Nations Security Council sanctions, European Union restrictive measures, United Kingdom sanctions administered by OFSI, United States sanctions administered by OFAC, and the domestic sanctions, export control, and AML law of the jurisdictions in which the Seller and Buyer Organizations are established or operate.
2.2 No exhaustive list published
2.2.1 Dynamic nature
- Sanctions lists change frequently. Gloseg does not publish a static list of Restricted Parties or Restricted Jurisdictions within this Policy. Organizations must maintain their own awareness of applicable restrictions relevant to their trade.
3. Prohibited parties and restricted jurisdictions
3.1 Prohibition
3.1.1 Core rule
- An Organization must not use the Platform if it is a Restricted Party, is majority owned or controlled by a Restricted Party, is established in a Restricted Jurisdiction subject to comprehensive sanctions, or intends a transaction that would benefit a Restricted Party.
3.2 Consequence of match
3.2.1 Immediate effect
- Any confirmed match against a Restricted Party or Restricted Jurisdiction results in immediate account suspension and a Screening Hold on any associated funds, pending compliance review.
4. Screening
4.1 Onboarding screening
4.1.1 When performed
- Screening is performed at Organization registration, at material profile changes (ownership, address, jurisdiction), and periodically thereafter.
4.2 Transaction-level screening
4.2.1 When performed
- Screening is also performed at Order formation and at each payment instruction, including Escrow funding and Payout, against current list data.
4.3 Payment holds and escrow freezes
4.3.1 Effect of a match
- A Screening match at any stage triggers a Screening Hold. Escrow funds associated with the transaction are frozen. Gloseg operations reviews the match manually before releasing, returning, or continuing to hold funds. No Payout is made while a Screening Hold is active.
5. Dual-use and controlled goods
5.1 Seller responsibility
5.1.1 Classification
- A Seller listing Dual-Use Goods or Controlled Goods is solely responsible for correctly classifying those goods under applicable export control lists and for holding any required export licence before listing or shipping.
5.2 Export licence responsibility
5.2.1 Gloseg's role
- Gloseg may request evidence of an export licence as part of Verification under the Verification & Trust Policy but does not issue, apply for, or guarantee the validity of any export licence. Responsibility for lawful export rests with the Seller, and responsibility for lawful import rests with the Buyer.
6. End-use and end-user assurances
6.1 Buyer assurance
6.1.1 Requirement
- Where a transaction involves Dual-Use Goods or Controlled Goods, Gloseg or the Seller may require the Buyer to provide an End-Use Assurance confirming the final destination, end use, and end user, and confirming the goods will not be diverted to a Restricted Party or Restricted Jurisdiction or to prohibited military or proliferation use.
6.2 Reliance and limits
6.2.1 No independent verification of end use
- Gloseg does not independently verify physical end use after delivery. Sellers should exercise reasonable commercial diligence on Buyer assurances proportionate to the sensitivity of the goods.
7. Diversion and transshipment red flags
| Red flag | Description |
|---|---|
| Unusual routing | Shipment routed through a jurisdiction with no logical commercial connection to buyer or goods |
| Reluctance to disclose end use | Buyer declines to state or evidence intended use of Controlled Goods |
| Mismatched buyer profile | Buyer's stated business activity is inconsistent with the goods ordered |
| Third-party payment | Payment instructed from an account or entity unrelated to the Buyer Organization |
| Urgent, unusually large orders from new accounts | Order pattern inconsistent with a newly onboarded Organization's stated scale |
| Request to omit or alter shipping documentation | Buyer or intermediary requests false declarations, mislabelling, or incomplete customs paperwork |
| Known high-risk destination | Final destination is a jurisdiction subject to sectoral or comprehensive sanctions |
7.1.1 Reporting red flags
- A Seller who identifies any red flag in this table should decline or pause the transaction and report it to legal@gloseg.com.
8. Documentary requirements
8.1 Standard set
8.1.1 Applicable documents
- Depending on the goods and jurisdictions involved, Gloseg or a counterparty may require business registration, export licence, End-Use Assurance, bill of lading or equivalent shipping documentation, and certificates of origin, consistent with the Verification & Trust Policy.
9. AML and counter-terrorist-financing expectations
9.1 FATF-aligned approach
9.1.1 Risk-based approach
- Gloseg applies a risk-based approach to anti-money laundering and counter-terrorist-financing consistent with Financial Action Task Force (FATF) recommendations, proportionate to transaction size, jurisdiction risk, and Organization profile.
9.2 Source-of-funds enquiries
9.2.1 When raised
- Gloseg operations may request evidence of source of funds for unusually large Escrow fundings, rapid repeated large transactions, or transactions inconsistent with an Organization's stated business activity or trading history.
9.3 Politically exposed persons
9.3.1 Enhanced diligence
- Where an Organization's beneficial owner or authorised representative is identified as a politically exposed person, enhanced due diligence applies, which may include additional documentation and closer transaction monitoring.
9.4 Prohibited payment channels
9.4.1 Restriction
- Payments through anonymous instruments, unregistered money service businesses, virtual assets not supported by Gloseg's payment infrastructure, or third parties unconnected to the Order counterparties are prohibited.
10. Record keeping
10.1 Retention periods
10.1.1 Standard
- Screening records, transaction records, and supporting compliance documentation are retained for the period required under applicable AML and sanctions record-keeping law in Ghana, Nigeria, the United Kingdom, and other relevant jurisdictions, and in any event for no shorter than five years from the date of the relevant transaction unless a longer period is legally mandated.
11. User obligations
11.1 Notification of changes
11.1.1 Trigger events
- An Organization must promptly notify legal@gloseg.com of any change in control, ownership, or beneficial ownership, any listing of the Organization or its principals on a sanctions list, and any regulatory action affecting its ability to trade lawfully.
11.2 Cooperation
11.2.1 Duty to cooperate
- An Organization must cooperate with lawful requests from Gloseg, regulators, or law enforcement relating to sanctions or trade compliance, including providing requested documentation within the timeframe specified.
12. Consequences of breach
12.1 Immediate suspension
12.1.1 Trigger
- Any confirmed breach of this Policy, including trading with a Restricted Party, shipping to a Restricted Jurisdiction, or providing false End-Use Assurances, results in immediate account suspension and a Screening Hold on associated funds.
12.2 Reporting
12.2.1 Escalation
- Confirmed breaches involving sanctions evasion, export control violations, or money laundering indicators are reported to the relevant competent authorities in Ghana, Nigeria, the United Kingdom, or other jurisdictions as applicable.
13. No advice; users must seek independent counsel
13.1 Disclaimer
13.1.1 No legal or compliance advice
- Nothing in this Policy constitutes legal, tax, export control, or compliance advice. Organizations are responsible for their own compliance with all applicable Sanctions Regimes, export control law, and AML law, and should seek independent professional advice specific to their trade.
14. Appeals and false-positive resolution
14.1 False positives
14.1.1 Process
- Where an Organization believes a Screening match is a false positive (for example, a name-only match unrelated to the Organization or its principals), it may submit clarifying identification information to legal@gloseg.com.
14.2 Indicative timeline
| Stage | Indicative duration |
|---|---|
| Acknowledgement of false-positive submission | 1 to 2 business days |
| Compliance review of clarifying information | 3 to 7 business days |
| Resolution and Screening Hold release, if cleared | Following completion of review |
14.3 Appeal of confirmed match
14.3.1 Right to appeal
- Where Gloseg maintains a Screening Hold following review, the Organization may appeal in writing to legal@gloseg.com with additional evidence. Appeals are reviewed by compliance personnel not involved in the original decision.
15. Enforcement and appeals
15.1 General authority
15.1.1 Discretion
- Gloseg operations may take any action reasonably necessary to manage sanctions and trade compliance risk, including holding funds, suspending accounts, and declining to process transactions, subject to the appeal rights in Section 14.
16. Amendments and notice
16.1 Updates
16.1.1 Notice
- Gloseg may amend this Policy at any time to reflect changes in applicable Sanctions Regimes or law. Material changes are notified through the Platform or by email, and take effect immediately where required by legal or regulatory obligation, or otherwise after fourteen days' notice.
17. Governing law and jurisdiction
17.1 Governing law
17.1.1 Primary law
- This Policy is governed by the laws of Ghana, without prejudice to the mandatory application of sanctions and export control law of the United Nations, European Union, United Kingdom, United States, and the jurisdictions of the Organizations involved.
17.2 Jurisdiction
17.2.1 Forum
- Subject to mandatory local law, the courts of Ghana have non-exclusive jurisdiction over disputes arising from this Policy.
Contact
Legal notices, questions about this document, data protection requests and compliance enquiries: legal@gloseg.com
Data subject requests may also be submitted through the Privacy & My Data surface at /privacy/my-data.
Gloseg B2B Limited Accra, Ghana, West Africa