Sanctions & AML Compliance Policy

Last updated: November 5, 2026

This policy is adopted by TuttareTech LLC, a limited liability company organized under the laws of the State of Colorado, United States (“TuttareTech”, “we”, “us”). It applies to every client, contractor and payment connected with our business.

1. Purpose and scope

TuttareTech provides IT consulting, website development and mobile app development to businesses. We are not a bank, a money services business or a money transmitter, and we do not hold or move funds on behalf of others. We receive payment only for our own services.

Even so, we take sanctions and anti-money laundering (AML) rules seriously. This policy explains the checks we run before and during every engagement.

2. Our commitment

We comply with the economic sanctions laws of the United States, including those administered by the Office of Foreign Assets Control (OFAC), and we also respect the sanctions of the European Union and the United Kingdom. We do not knowingly do business with, provide services to, or accept payments from any sanctioned person, entity or territory, and we do not take part in any arrangement designed to avoid these rules.

3. Who we do not work with

We do not provide services to, or accept payments from:

• persons or companies on the OFAC Specially Designated Nationals (SDN) list or other OFAC lists, the EU consolidated sanctions list, or the UK sanctions list, or companies owned 50% or more by such persons;
• persons or companies located in, or acting for, countries and regions under comprehensive U.S. sanctions, including Cuba, Iran, North Korea and the Crimea, so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine;
• persons located in the Russian Federation, in line with the U.S. prohibition on providing IT consultancy, design and related software services to persons there;
• anyone who will not tell us who they are or who the business is really owned by.

Sanctions programs change over time. We follow the lists as they stand when we check them, not as they are described on this page.

4. Sanctions screening

Before we sign an agreement or send the first invoice, we check the client company, its owners and the person signing against:

• the OFAC Sanctions List Search (sanctionssearch.ofac.treas.gov);
• the EU Financial Sanctions consolidated list;
• the UK Sanctions List.

We also screen every sender of funds to our accounts through a third-party sanctions screening service before the payment is accepted.

We repeat the check for every active client at least once a year, and again whenever the client’s owners, name, country or paying account change. We keep a record of each check. If there is a possible match, we pause the work and do not accept payment until the match is ruled out.

5. Knowing our clients

For every new client we collect and keep: the full legal company name, country and registration details, business address, the names of its owners and of the person signing on its behalf, and a short description of its business and the project. We confirm that the company exists in a public business register. We work only with businesses, not anonymous individuals.

6. Payments we accept

We accept payments only:

• for services set out in a signed agreement and a matching invoice;
• from the client named on the invoice, or from an account clearly owned by that client;
• in amounts that match the invoice.

Most payments are received in U.S. dollars by bank transfer. Where a client pays an invoice in stablecoins, we accept it only from a wallet the client has confirmed as its own, only through a regulated provider that performs its own sanctions screening, and we convert it to U.S. dollars. We do not accept cash, payments from unrelated third parties, or overpayments to be returned, and we do not exchange, hold or transfer digital assets or money for anyone else.

7. Warning signs and escalation

We stop and review an engagement if we notice, for example:

• a client unwilling to share ownership or company details;
• a request to pay from, or refund to, an unrelated person or a different country;
• payments much larger than the invoice, or split into unusual parts;
• links to a sanctioned country, person or region, including through IP addresses, contacts or delivery addresses;
• a project whose purpose appears unlawful.

If the concern cannot be cleared, we decline or end the engagement, refuse or return the payment through lawful channels, and cooperate with our bank and the relevant authorities. Where the law requires, we block funds and report them to OFAC.

8. Record keeping

We keep client details, screening results, agreements, invoices and payment records for at least five (5) years after the engagement ends.

9. Responsibility and review

The managing member of TuttareTech is responsible for this policy and for carrying out the checks it describes. Any contractor who works with our clients must follow it. We review this policy at least once a year and whenever sanctions rules change in a way that affects our business.

10. Contact us

Questions about this policy, or requests from banks and payment partners for further information: support@tuttare-tech.com. Postal address: 205 DETROIT STREET, DENVER, CO 80206.