Customer Agreement

HYH_TOP_TRADE_IBERICA_Sanctions and Compliance Policy Statement

Welcome to HYH TOP TRADE IBERICA SOCIEDAD LIMITADA (hereinafter referred to as "the Company" or "we"). As a professional in the global premium cigar industry, we are committed to upholding the highest standards of integrity, business ethics, and legal compliance in our business operations.

This Sanctions and Compliance Policy Statement aims to demonstrate our firm commitment to strictly complying with laws and regulations related to the cigar trade, including international trade sanctions, export controls, anti-money laundering (AML), and age restrictions on tobacco products.

  1. Compliance with international trade sanctions and export controls

We strictly abide by the economic and trade sanctions laws and regulations of major international organizations and relevant jurisdictions, including but not limited to:

United Nations Security Council (UNSC) resolutions, the Unreliable Entities List and export control regulations issued by the Chinese Ministry of Commerce and related departments, relevant sanctions regulations of the European Union (EU) and its member states, and relevant regulations of the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) (to the extent applicable) restricting destinations and entities: We will never participate in, assist, or support any commercial transactions, cargo transport, or financial transactions involving fully sanctioned countries or regions (e.g., Iran, North Korea, Syria, and related sanctioned regions in Ukraine). Furthermore, we refuse to transact with any individuals or entities on any international official restricted lists (such as the OFAC SDN list, the Chinese export control entity list, etc.).

Special note regarding the country of origin of cigars: We ensure that all products listed on this platform are legally sourced, have accurate and complete country of origin declarations, and do not violate any current trade embargoes or import/export restrictions applicable to the jurisdictions of the operating location and destination.

⚠ Key Disclaimer Clauses (Special Note):

Due to applicable legal restrictions, HYH TOP TRADE IBERICA SOCIEDAD LIMITADA does not mail or sell Cuban-origin products to or worldwide U.S. citizens. 2. Tobacco Control and Legal Age Verification

As a responsible cigar business, we strictly adhere to tobacco control laws worldwide and in various localities.

Minimum Purchase Age: We never sell cigars or any tobacco-related accessories to minors. Customers must be of legal smoking age in their local jurisdiction (e.g., 18 years old in Mainland China, the UK, and the EU; 21 years old in the US) to access or purchase products from this website. Age Verification Mechanism: We reserve the right to verify the buyer's identity through a secure and compliant third-party identity and age verification system before processing orders. 3. Cross-border Sales and Customs Compliance

The international transport of tobacco products such as cigars is subject to extremely strict customs supervision and restrictions.

Customer Responsibility: The customer (buyer) is responsible for ensuring that the imported cigars comply with local laws in their country or region. Customs Duties and Taxes: Cross-border parcels may be subject to import duties, excise taxes, and customs clearance fees levied by the destination country or region. All such fees are borne by the buyer. Confiscation and Return Risk: Our company assumes no legal or compensatory liability for parcels being detained, delayed, confiscated, or destroyed by local customs due to violations of the destination country's/region's tobacco import policies. 4. Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF)

We have a zero-tolerance policy towards any form of financial crime. We have implemented strict internal controls to prevent our platform from being used for money laundering or terrorist financing activities.

We only accept payments made through compliant, licensed, and reputable banks, credit card gateways, and third-party payment institutions. We absolutely do not accept anonymous payments, mailed cash, or "splitting/structured" payments designed to circumvent financial regulatory reporting limits. For any transaction suspected of fraud, money laundering, or failing our compliance and risk control review, we reserve the right to cancel the order and terminate the transaction at any time. 5. Violation Handling and Reporting Mechanism

Any attempt to circumvent our compliance review—including but not limited to using a VPN to forge a sanctioned region location, providing false age/identity verification, or deliberately splitting financial payments—will result in the immediate termination of your account, unconditional cancellation of related orders, and a permanent ban from accessing this platform.

If you have any questions about our compliance policy, or need to report any potential violations, please contact our legal and compliance team through the following methods:

Email: hyhtopsl@gmail.com  Company Address: Plaza de la constitucion 5, 35500