Trade Compliance & Sanctions

Version: 1.0
Last updated: August 20, 2026
Effective date: September 1, 2026
Website: https://www.hisicar.com

Important notice

HISICAR screens transaction parties, ownership, payers, banks, vehicles, technology, routes, vessels, consignees, final users and end use at multiple stages. Transactions involving Russia, Belarus, Central Asia or another elevated-risk route can require enhanced evidence because of diversion risk; nationality alone is not an automatic prohibition. A transaction can be paused or refused where necessary. Funds are handled under applicable law and are not automatically forfeited because of an alert.

1. Scope

This Policy applies to every HISICAR account, inquiry, PI, payment, vehicle, part, software/technical-data transfer, export, import-support service, shipment, warehouse service, resale arrangement, refund and after-sales activity.

It applies to Buyers, Buyer Users, beneficial owners, payers, consignees, notify parties, final users, agents, dealers, brokers, inspection/reconditioning providers, warehouses, freight forwarders, carriers and other transaction participants.

2. Applicable Trade Laws

“Applicable Trade Laws” means sanctions, export controls, import controls, customs, anti-boycott, anti-diversion, anti-bribery, anti-money-laundering, counter-terrorist financing and related mandatory requirements with a real connection to the transaction.

The connection may arise through:

• the PRC Seller/exporter;
• destination or transit country;
• Buyer, beneficial owner, payer, consignee or final user;
• bank, currency or payment provider;
• insurer, carrier, vessel, port or warehouse;
• origin of a vehicle, component, software or technology;
• a service provider’s jurisdiction; or
• another legally relevant fact.

HISICAR does not state that a foreign sanctions regime governs every transaction without a legal connection. A bank or provider can still restrict service under its terms and regulatory obligations.

3. Compliance responsibilities

3.1 Seller and exporter

The Seller and PRC exporter must:

• hold required authority and qualification;
• classify the vehicle and any controlled component/technology where necessary;
• obtain required PRC export licence;
• make truthful customs and regulatory declarations;
• screen the transaction under approved procedures;
• investigate red flags;
• retain evidence; and
• stop an unlawful transaction.

3.2 Buyer

The Buyer must:

• provide accurate and complete information;
• identify its ownership and control;
• identify the real payer, consignee, final user, end use, destination and route;
• obtain destination import, re-export and end-use approvals;
• prevent unlawful diversion;
• pass applicable restrictions to downstream parties; and
• preserve proof of import, delivery and end use.

3.3 Payment recipient and service providers

Hong Kong Racer House International Technology Limited, Stripe, banks, carriers and other providers can conduct independent screening and request information. Their screening does not replace the Seller/exporter’s review.

4. Information required

HISICAR may require:

• certificate of incorporation or business licence;
• registry extract, address, tax and licence information;
• genuine business activity and website;
• authorised signatory and power of attorney;
• directors, officers and controllers;
• shareholders and ultimate beneficial owners at 25% or a lower threshold required by risk or law;
• ownership/control chart;
• identity and address evidence for relevant individuals;
• payer, account holder and relationship to the Buyer;
• source of funds and, for elevated risk, source of wealth;
• consignee, notify party, importer, broker and downstream buyer;
• final user, end use and installation/use location;
• destination, transit route, ports, warehouse and resale plan;
• import/export/re-export permit and end-user certificate;
• vehicle VIN, HS/CN classification, value, origin and specifications;
• component, software, encryption, sensing, mapping and connected-vehicle functionality;
• carrier, vessel, freight forwarder and insurance details;
• purchase, shipping, customs, delivery and registration evidence; and
• an explanation for an inconsistency or red flag.

HISICAR collects only information proportionate to the risk and applies the Privacy Policy.

5. Beneficial ownership and control

Screening covers the legal entity and relevant owners/controllers. A person can be restricted because it is owned or controlled by a listed person even if the entity name does not appear on a list.

The Buyer must disclose direct and indirect ownership, nominee arrangements, trusts and other control rights. Concealing the true owner or decision-maker is a material breach.

A complex structure is not automatically prohibited, but it requires a clear commercial explanation and reliable evidence.

6. Screening sources

Depending on the transaction’s legal connections, HISICAR may screen:

• current PRC restricted, export-control and enforcement information;
• United Nations Security Council lists;
• European Union consolidated sanctions;
• United Kingdom Sanctions List;
• United States OFAC and export screening lists;
• destination and transit-country lists;
• lawfully obtained corporate and beneficial-ownership records;
• vessel, carrier and port information; and
• reliable adverse information relevant to fraud, corruption, diversion or prohibited trade.

The list and rule version used, date/time, search terms, reviewer and result are recorded.

A name similarity is not automatically a confirmed match. A possible match is resolved through identifiers, ownership, location and human review.

7. Screening stages

Risk-based screening is performed:

1. at account onboarding or inquiry;
2. before issuing a binding PI;
3. before accepting a deposit or material payment;
4. before incurring material procurement or reconditioning cost;
5. before booking shipment;
6. before export/customs submission;
7. before loading or departure;
8. before releasing title or documents;
9. before a refund to a changed route; and
10. whenever a party, owner, payer, destination, route, end use, law or risk changes.

An earlier clearance does not guarantee later clearance.

8. Buyer representations

The Buyer represents continuously that:

1. all information and documents are genuine, accurate, complete and current;
2. the Buyer and relevant transaction parties are not prohibited under Applicable Trade Laws and are not owned or controlled by a prohibited person;
3. the payment is legitimate and comes from an approved payer;
4. the stated destination, transit route, consignee, final user and end use are real;
5. no document, invoice, value, classification, origin, VIN or destination is false or misleading;
6. the vehicle, component, software, data or technology will not support a prohibited military, weapons, surveillance, security, human-rights-abusive or other restricted activity;
7. the Buyer will not evade restrictions through transshipment, relabelling, intermediaries, false registration, third-country warehousing or changed end use;
8. the Buyer will obtain required licences and approvals;
9. the Buyer will pass applicable resale/re-export restrictions to downstream parties; and
10. the Buyer will notify HISICAR immediately of any change.

These representations survive delivery for the period required by law and the accepted PI.

9. Final-user, end-use and route declaration

HISICAR may require a signed declaration identifying:

• Buyer and authorised signatory;
• beneficial owner;
• payer;
• consignee and notify party;
• importer and customs broker;
• final user and use address;
• intended commercial use;
• destination and transit route;
• warehouse and downstream resale plan;
• confirmation of no prohibited diversion or use;
• duty to notify changes;
• record-retention and audit commitment; and
• consequences of false information.

The declaration forms part of the Vehicle Sales Contract when incorporated by the PI.

10. Russia and Belarus

This Policy does not state that every vehicle transaction involving Russia or Belarus is prohibited. The result depends on current law, vehicle classification/specification, parties, ownership, banks, currency, origin content, route, carrier and end use.

An applicable Russia/Belarus transaction requires enhanced review, which can include:

• exact HS/CN classification and technical specifications;
• applicable luxury-goods, vehicle, component and technology restrictions;
• ownership/control and bank screening;
• final-user and commercial-use evidence;
• import licence and local registration plan;
• no-diversion and downstream covenant;
• route, vessel, insurer and port review;
• payment-currency and provider review; and
• fresh screening immediately before shipment and document release.

No party may use an intermediary or third country to make a prohibited transaction appear lawful.

11. Central Asia and other transshipment-risk routes

Kazakhstan, Kyrgyzstan, Uzbekistan, Tajikistan, Turkmenistan or another transit country is not automatically prohibited. Some transactions can present elevated circumvention risk.

Enhanced review can require:

• evidence of genuine local Buyer operations;
• local import/registration capacity;
• final user and use-site confirmation;
• warehouse operator and onward-sale controls;
• route and freight evidence;
• proof of duty/tax and import clearance;
• proof of local registration or delivery;
• downstream sanctions covenant; and
• post-delivery verification.

Refusal to identify the genuine customer, use or destination is a material red flag.

12. Red flags

Examples requiring investigation include:

• Buyer business unrelated to the vehicle or quantity;
• recently formed or dormant entity without explanation;
• hidden or frequently changing ownership;
• representative unable to explain the Buyer;
• unexplained personal, third-party or cash payer;
• payment from or refund to an unrelated country/account;
• overpayment followed by urgent redirected refund;
• split payments intended to avoid review;
• inconsistent names, addresses, licences or signatures;
• unusually complex route or high-risk transshipment;
• reluctance to identify final user or end use;
• request to remove VIN, destination or consignee data;
• under-invoicing or false classification request;
• change of destination after payment;
• refusal to provide import or delivery evidence;
• use inconsistent with vehicle specifications;
• military/security end-use indicators;
• sanctions-list similarity or listed ownership/control; or
• instructions to communicate only through an unverified intermediary.

A red flag does not always mean illegality, but it must be resolved before the controlled step proceeds.

13. Vehicle and technology classification

An ordinary passenger vehicle is not assumed to be export-controlled merely because it is a vehicle. Additional classification can be required for:

• military or special-purpose vehicle;
• armoured or ballistic protection;
• autonomous-driving or advanced sensing;
• high-performance or controlled component;
• encryption or cybersecurity technology;
• mapping or geospatial data;
• drone-support capability;
• surveillance equipment;
• remote-control functionality;
• diagnostic/source code; or
• connected-vehicle and technical data.

Physical export of a vehicle does not automatically authorise transfer of controlled software, source code, maps, diagnostic tools, technical data or Personal Data.

14. Import and local use

The Buyer is responsible for destination import, customs, conformity, tax, registration and lawful use unless the PI expressly assigns a service to the Seller.

The Buyer must not rely on general statements such as “EU standard,” “suitable for Africa” or “ready for export” as country-specific legal approval.

HISICAR may require an importer licence, conformity plan, emissions/safety evidence and confirmation that the vehicle can be registered and used at destination.

15. Payment integrity and AML controls

HISICAR does not describe every Group Company as a statutory anti-money-laundering reporting institution. Statutory status depends on the entity and applicable law.

HISICAR nevertheless applies risk-based payment controls and cooperates with regulated banks and payment providers.

Prohibited or elevated-risk conduct includes:

• anonymous payment;
• personal account payment;
• unexplained third-party payer;
• false trade or invoice;
• split/structured payment;
• unexplained cash;
• unexplained overpayment;
• rapid refund to a different party;
• forged remittance evidence; or
• inability to explain lawful funds.

The regulated institution can independently reject, freeze, reverse or report a transaction.

16. Cash

Cash is accepted only under the Payment Policy at an approved store, within legal limits, after required identity, payer and source-of-funds checks, through dual control and against a numbered receipt.

Third-party cash, couriered cash, employee collection, off-book receipt and payment splitting are prohibited.

17. Anti-bribery

No Group Company, Buyer, employee, agent, dealer, customs broker, inspection provider, warehouse, logistics provider or other intermediary may directly or indirectly:

• offer, promise, give, authorise, request or accept a bribe;
• pay or receive a kickback;
• make a facilitation payment;
• provide an improper gift, hospitality, travel, donation or sponsorship;
• use a false invoice, secret commission or off-book fund;
• conceal a conflict of interest; or
• use an intermediary to do what is prohibited directly.

This prohibition applies to public officials and private business decisions.

18. Gifts, hospitality, commissions and discounts

Any gift, hospitality, commission, sponsorship or discount must be:

• lawful;
• reasonable and proportionate;
• for a legitimate business purpose;
• accurately approved and recorded;
• not cash or cash-equivalent where prohibited;
• not intended to influence a decision improperly; and
• not offered during a sensitive licensing, inspection, customs or procurement decision without compliance approval.

Commission recipients and services must be real, documented and proportionate.

19. Agents, dealers and service providers

Risk-based due diligence is conducted before engaging a material agent, dealer, broker or service provider. Review can include:

• legal identity and ownership;
• qualifications and reputation;
• conflicts and government connections;
• scope, territory and compensation;
• sanctions and adverse information;
• bank account and payment method;
• anti-bribery and trade-compliance commitment; and
• monitoring/audit rights.

High-risk intermediaries require enhanced approval. Payment is made only for documented legitimate service to the contracted entity’s verified account.

20. Holds, refusal and termination

HISICAR may, where reasonably necessary:

• request additional information;
• pause account, PI, payment, preparation, shipment, refund or document release;
• reject a payer, route, carrier or service provider;
• require a lawful reroute;
• refuse or terminate a transaction; or
• make a legally required report.

Actions are proportionate to the risk and law. Reasons are given where lawful and safe.

No party is required to perform an unlawful act.

21. Funds during a compliance hold

A screening alert does not automatically allow HISICAR or a Seller to keep all money.

Funds are accepted, rejected, held, blocked, reported, returned or otherwise handled according to:

• applicable law;
• bank/payment-provider instruction;
• competent authority direction;
• accepted PI; and
• Payment Policy.

Where return is lawful, it normally goes to the verified original payer. Only lawful, disclosed and substantiated cost/loss may be deducted.

22. False information and circumvention

Providing a false identity, authority, owner, payer, destination, route, user, use, classification, value or document is a material breach.

HISICAR may terminate, preserve evidence, report where required and recover direct reasonable loss caused by the breach. This does not authorise an unlawful forfeiture or disclosure.

23. Record retention

HISICAR retains relevant compliance records for 10 years after transaction completion or termination, or longer where Applicable Trade Laws require.

Records include:

• source documents;
• search terms and sources;
• list/rule version;
• date and reviewer;
• possible-match analysis;
• beneficial ownership;
• risk rating and red flags;
• final-user/use and route evidence;
• approvals, holds and escalation;
• licences and customs documents;
• delivery/end-use evidence; and
• reports and authority correspondence.

Access is limited and logged under the Privacy Policy.

24. Monitoring and audit

The Buyer must preserve relevant corporate, payment, import, resale, route, delivery and end-use evidence and provide reasonable compliance confirmation.

An audit request must be proportionate, protect confidentiality and Personal Data, and focus on the transaction. HISICAR may use an independent professional reviewer.

25. Reporting concerns

Report suspected sanctions evasion, diversion, money laundering, bribery, false documents, payment fraud or retaliation to info@hisicar.com.

Good-faith reporting is protected from retaliation. A knowingly false malicious allegation can be addressed under applicable law.

HISICAR protects confidentiality to the extent possible but cannot promise anonymity where investigation, fairness or law requires disclosure.

26. Human review and appeal

A Buyer may request review of a HISICAR compliance decision through info@hisicar.com. The request should identify the transaction and provide reliable correcting evidence.

A reviewer not responsible for the original decision assesses the request where practicable. A provider’s independent decline must be appealed through that provider when HISICAR cannot reverse it.

Review does not require HISICAR to disclose confidential detection methods, another person’s data, privileged advice or information prohibited from disclosure.

27. Data protection

Compliance processing follows the Privacy Policy. Sensitive identity, ownership, financial and sanctions information is collected only where proportionate, protected through restricted access and retained under the approved schedule.

Cross-border screening and disclosure uses the transfer mechanism required by applicable privacy law.

28. Changes

This Policy is updated when law, risk, market, payment or route materially changes. A stricter mandatory rule applies immediately where legally required. A material contractual change to an accepted PI is handled through an amendment, not solely through a website update.

29. Contact

Trade compliance, screening review and confidential reports: info@hisicar.com.