Compliance Records - INTERNAL

F.A.F.O., LLC - GEAR

International Sales Compliance Record

Last Updated: September 2, 2026


1. OFAC SANCTIONS & PROHIBITED DESTINATIONS

We utilize established third-party payment processors (including Shopify Payments, Stripe, and/or PayPal) that perform real-time and ongoing OFAC/sanctions screening of merchants, customers, and transactions against applicable U.S. and international sanctions lists. These processors block or reject prohibited activity. In addition, as a U.S. LLC we maintain our own responsibility for OFAC compliance: we restrict sales to permitted jurisdictions only, avoid comprehensively sanctioned countries, and implement reasonable customer and order screening consistent with the nature and volume of our e-commerce business.

The following countries are excluded from our shipping zones and cannot complete checkout:

  • Cuba
  • Iran
  • North Korea (DPRK)
  • Russia
  • Syria
  • Belarus
  • Burma/Myanmar
  • Crimea, Donetsk, and Luhansk regions (Ukraine)

International shipments are fulfilled via DHL Express, FedEx, and DHL eCommerce — all of which maintain OFAC-compliant shipping policies and do not deliver to sanctioned destinations.

Shipping Zone Status (as of September 2, 2026): Rest of World catch-all zone removed. Replaced with 26 explicitly approved, OFAC-clean countries: AE, AT, AU, BE, CA, CH, CZ, DE, DK, ES, FI, FR, GB, HK, IE, IT, JP, KR, MY, NL, NO, NZ, PL, PT, SE, SG.


2. EXPORT CONTROL REVIEW

As of September 2, 2026, I reviewed all products in the F.A.F.O., LLC - GEAR catalog. All products consist of branded consumer apparel and accessories (hats, caps, and related merchandise). No items are subject to EAR, ITAR, or dual-use export restrictions.


3. CONSUMER DISCLOSURES

International customers are shown:

  • Local currency pricing at checkout
  • Notice that import duties and taxes may apply upon delivery and are the buyer's responsibility
  • Our return and refund policy
  • Our business address on all legal pages

Completed September 2, 2026:

  • Terms of Service placeholders filled (trading name, address, VAT marked N/A)
  • Business address added to Refund, Privacy, and Shipping policies
  • International duties/taxes notice added to Shipping and Refund policies

4. RECORD KEEPING

All order records, transaction histories, and customer data are retained automatically by Shopify. This compliance document is maintained internally and updated as business conditions change.

Pending: Password protection to be removed upon receipt of Sales Tax Certificate.


Full Compliance & Functionality Check — September 2, 2026

Area Status Notes
Export Control ✅ Pass All products confirmed non-restricted
OFAC Sanctions ✅ Pass Sanctioned countries blocked from shipping zones
Shipping Carriers ✅ Pass DHL Express, FedEx, DHL eCommerce — OFAC-compliant
Policy Pages ✅ Pass All 6 policies published with content
Business Address ✅ Pass Present in general settings and all policies
Consumer Disclosures ✅ Pass Duties notice in Shipping and Refund policies
International Markets ✅ Pass 25 approved countries, local currency enabled
Record Keeping ✅ Pass Compliance page maintained internally
Payment Provider ⚠️ Pending Shopify Payments not activated; resolution in progress
Storefront Access ⚠️ Pending Password protection ON — to be removed upon Sales Tax Certificate receipt

Signed: Nicholas Carrington, Owner — F.A.F.O., LLC - GEAR