Legal entity and governing framework
TF Federation Group LLC is a limited liability company registered in the State of Florida, United States. As a United States person, the company and its subsidiaries, officers and personnel are subject to United States federal law wherever they operate, including the Foreign Corrupt Practices Act (FCPA), the economic sanctions administered by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, and the federal prohibition on providing material support to designated organisations under 18 U.S.C. § 2339B.
Prohibited payments
The company does not make, offer, authorise or accept improper payments of any kind. This prohibition is not a matter of internal policy alone; it is a legal obligation with criminal consequences, and it applies equally to the company, to its subsidiaries and to any person acting on its behalf.
- Bribes, kickbacks and facilitation payments to public officials or private parties
- Payments demanded through coercion, intimidation or threat, in any jurisdiction
- Any payment, directly or indirectly, to an organisation or individual designated by the United States Government as a Foreign Terrorist Organisation (FTO), a Specially Designated Global Terrorist (SDGT) or a Specially Designated National (SDN)
- Any transfer of funds outside formal banking channels, against documented invoices
Several organised criminal groups operating in the region where the group maintains offices are currently designated by the United States Government under the categories referred to above. Payments to such groups constitute a federal offence for a United States person, irrespective of the circumstances in which they are demanded and irrespective of the country in which the demand is made. The company therefore has no legal discretion to make such payments.
Cash and site controls
- No cash is held at company premises, and no payment is made in cash
- All disbursements are executed through banking channels against documented invoices
- Personnel hold no authority to negotiate, authorise or settle any payment demand
Reporting
Any attempt to obtain a payment through coercion, intimidation or threat, directed at the company, its personnel or its facilities, is reported to the competent authorities of the jurisdiction concerned and, where applicable, to the competent authorities of the United States. Extortion and kidnapping are serious criminal offences under the Ecuadorian Código Orgánico Integral Penal, as they are under the laws of the other jurisdictions in which the group operates.
Compliance and reporting channel
Suspected breaches of this notice, by personnel, suppliers or third parties, may be reported in confidence to info@tf-ims.com.
References: Foreign Corrupt Practices Act, 15 U.S.C. §§ 78dd-1 et seq. · 18 U.S.C. § 2339B · Executive Order 13224 · International Emergency Economic Powers Act, 50 U.S.C. § 1701 et seq. · Código Orgánico Integral Penal del Ecuador, Arts. 161, 162 and 185.