Sanctions & Trade Compliance Policy
1. Scope
Fortune Imports and Exports (India), operating as Fortune Sourcings ("Company"), is committed to full compliance with all applicable sanctions, export-control, and anti-money-laundering laws, including but not limited to: US OFAC sanctions programmes; EU restrictive measures under Council Regulations; UK HM Treasury / OFSI sanctions; UN Security Council sanctions; the Foreign Trade (Development & Regulation) Act, 1992 (India) and the Foreign Exchange Management Act, 1999 (India); and China's Export Control Law.
2. Client screening (KYC)
Before onboarding any client and, thereafter, at reasonable intervals, we screen the client, its directors, officers and beneficial owners against applicable sanctions lists (OFAC SDN, EU Consolidated List, UK OFSI, UN Consolidated List, India MEA sanctions list) and adverse-media sources. Where a screening hit or reasonable suspicion arises, the engagement is escalated to the CEO before any Services commence.
3. Vendor & counterparty screening
The same screening is applied to every factory, trader, agent, freight forwarder and customs broker in our supply chain. Vendors located in comprehensively sanctioned jurisdictions (currently Iran, North Korea, Syria, Cuba, and the non-government-controlled areas of Ukraine's Crimea, Donetsk, Luhansk, Kherson and Zaporizhzhia regions) are not eligible to receive orders through Fortune Sourcings.
4. Product-level export controls
The Client is solely responsible for classifying its goods against applicable export-control regimes (US EAR, EU Dual-Use Regulation, Wassenaar Arrangement, MTCR, NSG, India SCOMET). Where a product may be classified as dual-use or controlled, the Client shall obtain the necessary licences at its own cost and provide copies to Fortune Sourcings before shipment. We reserve the right to decline any engagement where we reasonably believe a control classification is being under-declared.
5. Diversion & end-use assurance
The Client warrants on a continuing basis that goods sourced through Fortune Sourcings shall not be re-exported, transferred or on-sold to any Sanctioned Person or in any manner that would constitute a breach of any applicable sanctions or export-control law. Any request to divert goods to a destination or party different from the original Order Form must be pre-approved by Fortune Sourcings and may trigger renewed screening.
6. Financial-crime & AML
We accept payments only from bank accounts that are demonstrably owned by the contracting Client (or from an entity documented as a related payer). We do not accept payments in cash, cryptocurrency, or via third-party intermediaries. Any indication of layered payment structures, unexplained multi-jurisdictional flows, or beneficial-ownership opacity is grounds for immediate suspension of Services and, where required, a suspicious-activity report to the relevant authority.
7. Escalation & termination
The Company may refuse to onboard, suspend, or terminate any engagement at its sole discretion where it reasonably believes performance may breach any applicable sanctions, export-control, or AML law. In such cases, any funds already received are refunded net of costs actually incurred; the Client waives any claim for further compensation.
8. Reporting
Any concern regarding the compliance of a Fortune Sourcings engagement with sanctions or export-control law may be reported in confidence to compliance@fortunesourcings.com.
