Terms and Conditions of Website Use and Service

Version: Version 3.0
Last updated: 2 October 2026
Published at: tudorsgroup.com/terms (anchors listed in Part C)
Language: these Terms are drafted in English. Translations are provided for convenience; if a translation differs from the English text, the English text prevails (Section B33).

Preliminary statement

These Terms and Conditions of Website Use and Service (the "Terms") govern (i) the use of the website tudorsgroup.com and its language versions (the "Site") and (ii) every service that a business customer books, buys or commissions from T&T through the Site, by accepting a written Quote, or by any other written means that refers to these Terms.

"T&T" is the trade name of a group of companies. The company that provides, invoices and collects payment for every Service under these Terms is T&T Consulting Business, LLC, a limited liability company organized under the laws of the State of Florida, United States, with its address at 13575 58th St N, Suite 200, Clearwater, Florida 33760, United States (Section B3). The business is directed from Split, Croatia. Contact for these Terms: Dinko Anton Tudor, Managing Member, legal@tudorsgroup.com, telephone +1 813 384 8490.

The Terms are organized in three Parts:

IMPORTANT NOTICE. THESE TERMS CONTAIN AN AGREEMENT TO RESOLVE DISPUTES BY BINDING INTERNATIONAL ARBITRATION SEATED IN MIAMI, FLORIDA, WITH LIMITED EXCEPTIONS FOR THE COURTS OF MIAMI-DADE COUNTY (SECTION B29), A CHOICE OF FLORIDA LAW (SECTION B28), A WAIVER OF TRIAL BY JURY (SECTION B30), A WAIVER OF CLASS, COLLECTIVE AND CONSOLIDATED PROCEEDINGS (SECTION B31), A DISCLAIMER OF IMPLIED WARRANTIES (SECTION B19) AND A LIMITATION OF LIABILITY (SECTION B20). PLEASE READ THEM BEFORE ACCEPTING.

Definitions and interpretation

1. Definitions. In these Terms, the following capitalized words have the meanings given below.

2. Interpretation.
2.1 Headings are for convenience only and do not affect interpretation.
2.2 "Including" and similar words mean "including without limitation".
2.3 "Written" and "in writing" include email and messages sent through the Site, but not instant messaging applications unless T&T confirms otherwise in writing.
2.4 References to a statute or regulation are references to it as amended or replaced from time to time.
2.5 A reference to a Section is to a Section of these Terms; references beginning with A, B or C are to the corresponding Part.
2.6 Where a period is expressed in hours, it runs continuously, 24 hours a day, including non-Business Days.

Part A · Use of the Site

A1. Scope of Part A. Part A applies to every person who accesses or uses the Site, whether or not that person books or buys a Service. By using the Site you accept Part A. If you do not accept it, do not use the Site.

A2. Information, not advice.
A2.1 The content of the Site, including Service descriptions, articles, guides (Section C11) and the answers given by the Site assistant (Section C10), is general information about business, trade and regulatory processes. It is provided for orientation only.
A2.2 Site content is not legal, tax, accounting, investment, securities or financial advice. It is not tailored to your circumstances, may not reflect the most recent changes in law or practice, and must not be relied on as a substitute for advice obtained for your specific matter.
A2.3 No professional relationship of any kind arises from reading Site content, from using the Site assistant, or from sending a form, until an Engagement is formed under Section B4.

A3. Acceptable use. You must not, and must not allow anyone acting for you to:
(a) use the Site for any purpose that is unlawful, fraudulent or in breach of Applicable Sanctions Laws or AML Laws;
(b) submit false, misleading or impersonated information, including information about a Counterparty that you have no right to share;
(c) upload files that contain malware, or any content that is unlawful, infringing or obtained in breach of confidentiality;
(d) probe, scan or test the vulnerability of the Site or of the systems that support it, or breach or circumvent any security or authentication measure, except under a written authorization from T&T;
(e) interfere with the operation of the Site, including by automated requests, scraping, crawling beyond what the Site's robots.txt file permits, or denial-of-service activity;
(f) collect personal data about other users or about persons named on the Site;
(g) impersonate T&T, any of its members, or any person acting for T&T, or present any offer, document or payment request as coming from T&T when it does not (see Section C7.4); or
(h) use the Site or its content to train, fine-tune or evaluate machine-learning models without T&T's prior written consent.

A4. Suspension of access. T&T may block, restrict or suspend access to the Site or to any of its forms, without notice, where it reasonably believes that a person is in breach of Section A3, or where necessary to protect the Site, T&T or other users.

A5. Intellectual property in the Site.
A5.1 The Site, its text, structure, design, graphics, code, databases, the names "T&T", "T&T Consulting" and "iSkra", and all logos are owned by or licensed to T&T and are protected by copyright, trademark and other laws, including the U.S. Copyright Act (17 U.S.C. §101 et seq.) and the Lanham Act (15 U.S.C. §1051 et seq.). These names are used as unregistered trade names and marks; no registration is claimed.
A5.2 You may view the Site, link to any public page, and quote short extracts with attribution to T&T and a link to the source. Any other copying, reproduction in bulk, republication, framing or commercial use requires T&T's prior written consent.

A6. Feedback. If you send suggestions about the Site or the Services, T&T may use them without obligation to you. This does not apply to Confidential Information or to Customer materials provided under an Engagement.

A7. Third-party links and services. The Site links to and relies on third-party services (including Stripe for payments and Google Meet for Consultations). Those services are governed by their own terms and privacy notices. T&T does not control and is not responsible for third-party websites or their content.

A8. Availability and accuracy. T&T aims to keep the Site available and its content accurate and current, but does not warrant that the Site will be uninterrupted, secure or free of errors, or that content (including prices and regulatory references) is complete or up to date at every moment. T&T may change, suspend or withdraw any part of the Site at any time. The price that binds T&T is the price confirmed at the Payment Time or in an accepted Quote.

A9. Privacy and cookies. The processing of personal data through the Site is described in the Privacy Policy and in the Cookie Policy, which are separate documents and do not form part of the contract with you. The Site does not set its own cookies; its browser storage and consent mechanism are described in the Cookie Policy.

A10. Disclaimer for Site use. THE SITE AND ITS CONTENT ARE PROVIDED "AS IS" AND "AS AVAILABLE". TO THE FULLEST EXTENT PERMITTED BY LAW, T&T DISCLAIMS ALL WARRANTIES REGARDING THE SITE, EXPRESS OR IMPLIED, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. T&T WILL NOT BE LIABLE FOR ANY LOSS ARISING FROM THE USE OF, OR RELIANCE ON, FREE SITE CONTENT, EXCEPT TO THE EXTENT THAT SUCH LIABILITY CANNOT BE EXCLUDED BY LAW.

A11. Law and disputes for Part A. Sections B28 (governing law), B29 (dispute resolution), B30 (waiver of jury trial) and B31 (individual proceedings only) apply to Part A.

Part B · General conditions of service

B1. Order of precedence

B1.1 The documents that make up an Engagement apply in the following order of precedence, the earlier prevailing over the later in case of conflict:
(a) any agreement signed by both parties specifically for the matter concerned (for example an engagement letter, a mandate, an NCNDA or a sale and purchase agreement), but only for its subject matter;
(b) the accepted Quote;
(c) the Part C section applicable to the Service;
(d) the Service Page;
(e) Part B;
(f) Part A.
B1.2 Notwithstanding Section B1.1, where a Service Page grants the Customer a refund or credit more favorable than Section B8, that more favorable term applies.
B1.3 Section C1 (Consultations) prevails over any other provision of these Terms concerning the booking, payment, cancellation, rescheduling and crediting of Consultations.
B1.4 The Privacy Policy and the Cookie Policy are information notices. They are not contractual terms and nothing in them is varied by these Terms.

B2. Business customers only

B2.1 The Services are offered exclusively to businesses and professionals acting for purposes relating to their trade, business, craft or profession. T&T does not offer Services to Consumers.
B2.2 By booking, ordering or accepting a Quote, the Representative declares that the Customer is not a Consumer and that the Service is acquired for business purposes. T&T relies on this declaration when it accepts the Engagement and when it applies the business-to-business provisions of these Terms, including Sections B8, B20, B29, B30 and B31.
B2.3 T&T may ask for evidence of business status (for example a company registration number, a VAT or tax identification number, or a business email domain) and may decline or cancel an Engagement where that evidence is not provided.
B2.4 Safeguard if a Consumer contracts. If, despite Section B2.1, an Engagement is concluded by a person who is a Consumer under the law of his or her habitual residence:
(a) nothing in these Terms deprives that person of the protection of provisions that cannot be derogated from by agreement under the law of the country of habitual residence, where that law applies under Article 6 of Regulation (EC) No 593/2008 (Rome I) or under equivalent rules elsewhere;
(b) in the European Union, this may include the information requirements and the right of withdrawal under Directive 2011/83/EU on consumer rights (Articles 9 to 16), the unfair-terms control of Council Directive 93/13/EEC, and the right of the Consumer to sue and be sued in the courts of the Member State of domicile under Articles 17 to 19 of Regulation (EU) No 1215/2012 (Brussels I bis);
(c) Sections B8.2, B20, B29, B30 and B31 apply to that person only to the extent permitted by those mandatory provisions; and
(d) T&T may, on becoming aware of Consumer status, terminate the Engagement and refund in full any amount paid for work not yet performed, without prejudice to any greater right the Consumer has by law.

B3. The contracting T&T entity

B3.1 Every Engagement, for every Service listed in Part C, is concluded with T&T Consulting Business, LLC, which performs or procures the Services, issues receipts and invoices, collects all payments and holds the Stripe account through which payments are made. References to "T&T" in an Engagement are references to T&T Consulting Business, LLC.
B3.2 Tudor & Tudor, LLC, a Florida limited liability company of the same group, is not a party to any Engagement and assumes no contractual obligation to the Customer under these Terms. Its role is limited to acting as joint controller of personal data with T&T Consulting Business, LLC, as described in the Privacy Policy (Section B17.1).
B3.3 Food and beverage products offered on the Adriatic pages of the Site are sold by Tudor Adriatic d.o.o. (Split, Croatia), under its own conditions, as provided in Section C8. Tudor Adriatic d.o.o. is not a party to any Engagement under these Terms.

B4. Acceptance and formation of the contract

B4.1 Invitation to treat. Service Pages, prices and descriptions on the Site are an invitation to place an Order or request a Quote. They are not binding offers.
B4.2 Formation. An Engagement is formed:
(a) for Orders and Bookings, at the Payment Time, provided that the Representative has ticked the box confirming acceptance of these Terms and of the Service Page during checkout; or
(b) for Services sold by Quote, when the Customer accepts the Quote in writing and, where the Quote requires an advance payment, when that payment is received.
B4.3 Electronic contracting. The parties agree to conduct the transaction by electronic means. Each party agrees that electronic records and electronic signatures, including the act of ticking an acceptance box, clicking a payment button or replying "accepted" to a Quote by email, have the same legal effect as a handwritten signature and a paper record, under the U.S. Electronic Signatures in Global and National Commerce Act (15 U.S.C. §7001 et seq.) and the Florida Uniform Electronic Transaction Act (Fla. Stat. §668.50), and, where relevant, Regulation (EU) No 910/2014 (eIDAS). Neither party will contest the validity or enforceability of an Engagement on the sole ground that it was formed electronically.
B4.4 Records. T&T keeps an electronic record of each acceptance (the version of these Terms and of the Service Page, the date and time, and the email used). On request T&T will send the Customer a copy of the Terms version that applies to its Engagement.
B4.5 Right to decline. T&T may decline any Order, Booking or request for a Quote before or after the Payment Time, in particular under Section B7. If T&T declines after payment, it refunds the full amount paid, except where Section B7.4 (blocked funds) applies.
B4.6 Errors. If an obvious error in price or description is discovered before work starts, T&T will inform the Customer, who may confirm the Order at the correct price or cancel it with a full refund.

B5. Capacity and authority of the Representative

B5.1 The Representative declares that he or she is at least 18 years old, has legal capacity, and is authorized to bind the Customer to these Terms and to the Engagement.
B5.2 If the Representative lacks that authority, the Representative is personally bound by the Engagement and liable to T&T for any loss caused by the lack of authority, to the extent permitted by law.
B5.3 The Customer is bound by instructions and information given by its Representative and by any person whom the Representative introduces to T&T as acting for the Customer.

B6. Nature of the Services

B6.1 Business consulting and verification. T&T provides business consulting, commercial verification, regulatory filing support and related administrative services.
B6.2 No legal services. T&T is not a law firm. T&T does not practice law, does not give legal advice and does not represent the Customer before any court. No attorney-client relationship is created by any Engagement, by any communication with T&T, or by the fact that any member or personnel of T&T holds a law degree or a professional qualification in any jurisdiction. Communications with T&T are not protected by attorney-client privilege or the work-product doctrine. In the State of Florida, the practice of law is reserved to members of The Florida Bar (Rules Regulating The Florida Bar, Chapter 10; Fla. Stat. §454.23), and T&T does not hold itself out as authorized to practice law in Florida or in any other jurisdiction.
B6.3 Referral to counsel. Where a matter requires legal advice, representation, a legal opinion or the drafting of a legal instrument tailored to the Customer's rights, T&T will tell the Customer so. If the Customer engages a lawyer recommended by T&T, that engagement is a separate contract directly between the Customer and the lawyer; T&T is not responsible for the lawyer's advice.
B6.4 No tax, investment or securities advice. T&T does not provide tax, accounting, audit, investment, securities, brokerage, banking or insurance advice or services. T&T is not a registered investment adviser, broker-dealer, commodity trading advisor, futures commission merchant, money transmitter or escrow agent, and does not hold or transmit funds on behalf of the Customer or of any Counterparty.
B6.5 Not a guarantee. Deliverables reflect the information available and verifiable at their date. T&T does not guarantee the performance, solvency or honesty of any Counterparty, the outcome of any transaction, or any decision of a government agency (Section B11).
B6.6 Customer decisions. The Customer remains solely responsible for its own commercial, legal, financial and regulatory decisions, including whether to enter into any transaction.

B7. Compliance: sanctions, AML and KYC

B7.1 Customer obligations. The Customer represents, warrants and undertakes, throughout each Engagement, that:
(a) neither the Customer, nor any of its owners holding 50% or more (individually or in the aggregate), directors, officers or Representatives, is a person listed on, or owned or controlled by a person listed on, the OFAC Specially Designated Nationals and Blocked Persons List, the EU Consolidated Financial Sanctions List, the UK Consolidated List or any similar list under Applicable Sanctions Laws, nor is located, organized or ordinarily resident in a country or territory subject to comprehensive sanctions;
(b) it will not use any Service, Deliverable or introduction, directly or indirectly, for any transaction, dealing or activity involving a sanctioned person, country or territory, or that would cause T&T to breach Applicable Sanctions Laws or AML Laws;
(c) the funds it uses to pay T&T are of lawful origin;
(d) it complies with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (15 U.S.C. §78dd-1 et seq.), and will not offer or request any improper payment in connection with any Engagement; and
(e) it will inform T&T promptly in writing if any of the above ceases to be true.
B7.2 Know-your-customer and sanctions screening. T&T may, before and during an Engagement, request identification and ownership information about the Customer, its beneficial owners and the transaction. As part of the acceptance of every Customer, and of every due diligence Service, T&T screens the Customer and, where relevant, the Counterparty against the OFAC Specially Designated Nationals and Blocked Persons List and the other OFAC consolidated sanctions lists, the United Nations Security Council Consolidated List, and the restrictive measures of the European Union, and may consult other public lists.
B7.3 Right to refuse, suspend or terminate. T&T may refuse to accept an Engagement, suspend work, or terminate an Engagement with immediate effect by written notice, without liability, where: (a) the Customer does not provide KYC information requested within a reasonable time; (b) T&T reasonably believes that performing or continuing the Engagement would or could breach Applicable Sanctions Laws or AML Laws or expose T&T to sanctions risk; (c) a representation in Section B7.1 is or becomes untrue; or (d) T&T reasonably suspects fraud or the use of the Services for an unlawful purpose.
B7.4 Consequences. On termination under Section B7.3, T&T refunds the Fees for work not yet performed, except (a) where the termination results from the Customer's breach of Section B7.1, in which case Section B8 applies as if the Customer had cancelled, and (b) where Applicable Sanctions Laws require T&T to block or reject funds, in which case T&T will block or reject them and file the reports required by law, including under 31 C.F.R. §§501.603 and 501.604, and will not release them except as authorized by OFAC.
B7.5 No tipping off. T&T is not required to give reasons for a decision under Section B7.3 where giving reasons would be unlawful or would prejudice a legal obligation.

B8. Prices, taxes, payment and chargebacks

B8.1 Currency and price. All Fees are stated and payable in United States dollars (USD). The Fees applicable to an Engagement are those shown at the Payment Time or in the accepted Quote. Prices marked "from" are indicative minimums; the final price is set in a Quote.
B8.2 Third-Party Fees. Third-Party Fees are not included in the Fees. Where T&T pays Third-Party Fees on the Customer's behalf, they are shown separately before payment or in the Quote, and are charged at cost, without any mark-up, handling charge or commission added by T&T.
B8.3 Payment. Orders and Bookings are paid in full at checkout through Stripe, Inc. or its affiliates, either on Stripe Checkout, a payment page hosted by Stripe, or in Stripe's payment form embedded in the Site. T&T does not receive or store card details. Services sold by Quote are payable as stated in the Quote (by Stripe payment link or bank transfer).
B8.4 Receipts and invoices. Stripe issues a receipt for every payment. T&T Consulting Business, LLC issues an invoice on request sent to legal@tudorsgroup.com within ninety (90) days after the Payment Time, stating the Customer's legal name, address and tax identification number. Invoices requested after that period are issued only where the law requires it.
B8.5 Taxes.
(a) Fees are exclusive of any sales, use, value-added, goods and services or similar taxes. The Customer pays any such tax that applies, in addition to the Fees.
(b) Florida sales and use tax. Florida sales and use tax applies to the services enumerated in Chapter 212 of the Florida Statutes, including the detective, investigation and protection services listed in Fla. Stat. §212.05(1)(i). Business consulting services are not among the enumerated services. Where Florida law makes a Service, or part of it, taxable, the tax is shown separately before payment or in the Quote and is charged at the rate in force on the date of the supply.
(c) European Union VAT. Where the Customer is a taxable person established in a Member State of the European Union and the place of supply of the Service is the place where the Customer is established under Article 44 of Council Directive 2006/112/EC, the Customer accounts for the VAT under the reverse-charge mechanism of Article 196 of that Directive. The Customer must provide a valid VAT identification number, which T&T may check on the VIES system, and the invoice will state "Reverse charge". Where the reverse charge does not apply, T&T charges VAT where and as the law applicable to the supply requires, and the VAT is shown separately before payment or in the Quote.
(d) Withholding. All payments are made without deduction or withholding of any tax, unless the deduction is required by law. If the Customer is required to withhold, it pays T&T the additional amount necessary so that T&T receives the full Fees it would have received without the withholding, and provides T&T with the official receipt of payment of the withheld tax.
B8.6 Bank and conversion charges. Currency conversion, bank and transfer charges on the Customer's side are borne by the Customer.
B8.7 Late payment (Quotes). Amounts due under a Quote and not paid by the due date bear interest at one percent (1%) per month, or at the maximum rate permitted by law if lower, from the due date until the date of payment, and T&T may suspend work until payment.
B8.8 Chargebacks and payment disputes.
(a) Before disputing a payment with its card issuer or bank, the Customer agrees to contact T&T at legal@tudorsgroup.com and give T&T ten (10) Business Days to resolve the matter.
(b) A chargeback or payment dispute that is not justified under these Terms (including one initiated after the cancellation periods of Section B9 have expired, or for a Service that was delivered) is a breach of the Engagement.
(c) T&T may contest any chargeback by submitting to Stripe and the card network the record of acceptance kept under Section B4.4, the Service Page, the Deliverables and the relevant correspondence.
(d) While a chargeback is pending, T&T may suspend performance of all Engagements with the Customer.
(e) If a chargeback is resolved in T&T's favor, or if the Customer withdraws it, the Customer reimburses T&T for the dispute fees that Stripe charged and did not return for that chargeback, under the Stripe pricing in force at the time, as evidenced by Stripe's records. If a chargeback is resolved in the Customer's favor for an amount greater than that due under Section B9, the difference remains a debt owed to T&T.

B9. Cancellations and refunds

B9.1 Consultations. Cancellations, rescheduling and credits for Consultations are governed exclusively by Section C1.
B9.2 Other Services: the 24-hour rule. For every Service other than Consultations:
(a) the Customer may cancel the Engagement within twenty-four (24) hours after the Payment Time (or, for Services sold by Quote, after the time at which T&T receives the first payment); in that case T&T refunds seventy percent (70%) of the Fees paid, whether or not work has started;
(b) the 24-hour period is computed continuously from the Payment Time as recorded by Stripe, including weekends and holidays; the confirmation email states the Payment Time and the exact time at which the period ends, in Coordinated Universal Time (UTC);
(c) a cancellation is timely if it is received by T&T before the end of the period, by a reply to the confirmation email or by an email to legal@tudorsgroup.com, in either case sent from the email address used for the Order; the time of receipt recorded by T&T's systems governs; and
(d) after the 24-hour period, the work is deemed to be in progress and no part of the Fees is refunded, except as provided in Section B9.3.
B9.3 Exceptions stated on the Service Page. Section B9.2 does not reduce any refund that the Service Page or Part C expressly grants, which currently includes:
(a) a full refund of the Fees for a due diligence report where the Counterparty was introduced to the Customer by T&T (Section C2.6); and
(b) a refund of thirty percent (30%) of the Fees for a due diligence report delivered after the deadline stated on the Service Page (Section C2.7).
Refunds under different provisions for the same Engagement are not cumulative; the Customer receives the highest applicable refund, and never more than 100% of the Fees paid.
B9.4 Third-Party Fees. Third-Party Fees that T&T has already filed, paid or irrevocably committed to an agency, registry or third party are not refundable in any case, including within the 24-hour period. Third-Party Fees collected but not yet filed or paid at the time of a valid cancellation are refunded in full. The 70% refund under Section B9.2(a) is computed on the Fees only.
B9.5 Annual Services. For annual Services (Sections C4 and C5), Section B9.2 applies to each annual term from its Payment Time. No pro rata refund is made for the unused part of a term. Annual Services do not renew automatically (Sections C4.9 and C5.9).
B9.6 Cancellation by T&T. If T&T cancels an Engagement for reasons not attributable to the Customer and not covered by Sections B7 or B24, it refunds the Fees for work not yet delivered in full.
B9.7 Method and timing. Refunds are made to the original payment method through Stripe (or, for bank transfers, to the account from which payment was made), normally within ten (10) Business Days of the cancellation. The time the funds take to appear depends on the Customer's bank or card issuer. T&T does not deduct Stripe processing fees or any other charge from refunds; the percentages in this Section B9 are applied to the Fees actually paid.

B10. Timelines and suspension

B10.1 Estimates and deadlines. Timelines on the Site are estimates unless the Service Page or the Quote expressly states a deadline. Deadlines expressed in Business Days start on the Business Day after the Payment Time, unless the Service Page provides otherwise.
B10.2 Suspension while information is missing. Every timeline and deadline is suspended from the moment T&T asks the Customer in writing for information, documents, signatures or payments necessary to perform the Service, until the moment T&T receives a complete response. The confirmation email and T&T's requests will state what is missing.
B10.3 Other suspensions. Timelines are also extended by any delay caused by (a) a government agency, registry or third-party system (including outages or closures of the FDA, IRS, USDA, TTB, OFAC or state registry systems), (b) a Counterparty that does not respond, where the Service depends on its cooperation, or (c) an event under Section B24.
B10.4 Customer delay beyond 90 days. If the Customer does not provide information requested for more than ninety (90) days, T&T may close the Engagement by written notice. The Fees are not refunded, but T&T delivers any work completed at the time of closure.

B11. Third parties and agencies

B11.1 Decisions on registrations, permits, licenses, approvals, admissibility of goods, inspections, alerts and enforcement belong exclusively to the competent agencies, including the U.S. Food and Drug Administration (FDA), the U.S. Department of Agriculture (USDA), the Alcohol and Tobacco Tax and Trade Bureau (TTB), the Internal Revenue Service (IRS), OFAC and state registries.
B11.2 T&T does not guarantee any approval, registration, license, outcome or timing of an agency.
B11.3 T&T is not responsible for the acts or omissions of agencies, registries, banks, carriers, inspection companies, Counterparties or other third parties not engaged by T&T as its subcontractors.

B12. Customer obligations

The Customer must:
(a) provide complete, accurate and current information and documents, and promptly correct any information that becomes inaccurate;
(b) ensure that it has the right to provide to T&T all information and documents it supplies, including personal data and confidential information of third parties (including Counterparties, employees and suppliers), and that it has complied with any notice, consent or other requirement of applicable data protection law and of any confidentiality obligation in doing so;
(c) respond to T&T's requests within a reasonable time;
(d) review Deliverables and filings prepared for its signature or approval before approving them, and inform T&T of any error before filing;
(e) comply with its continuing legal obligations, including those described in Part C;
(f) not use any Service for an unlawful purpose or in breach of Section B7; and
(g) inform T&T immediately if it learns that any information provided is false, or that a Deliverable is being used in a way that breaches Section B14.

B13. Deliverables

B13.1 Form. Deliverables are delivered electronically, normally by email from a tudorsgroup.com address, in PDF or another agreed format.
B13.2 Date of a Deliverable. Each Deliverable speaks as of its date. T&T has no obligation to update a Deliverable after delivery for later events, changes in law or sanctions lists, or new information, unless the Service includes monitoring or the parties agree an update in writing.
B13.3 Acceptance. The Customer may report in writing any material non-conformity of a Deliverable with the description of the Service within ten (10) Business Days of delivery. T&T will correct it within a reasonable time. If no report is made within that period, the Deliverable is deemed accepted, without prejudice to Section B18.

B14. License of use and no third-party reliance

B14.1 License. On payment of the Fees, T&T grants the Customer a non-exclusive, non-transferable, non-sublicensable, worldwide and perpetual license to use the Deliverables for its internal business purposes in connection with the decision or matter for which they were prepared.
B14.2 Permitted disclosure. The Customer may disclose a Deliverable (a) to its own officers, employees, legal, tax and financial advisers, auditors and insurers who need to know it and are bound by confidentiality, (b) to a bank or financing institution in connection with the transaction concerned, on a non-reliance basis, and (c) where required by law or by a competent authority.
B14.3 No reliance by third parties. Deliverables are prepared solely for the Customer. No third party (including any Counterparty, financier, buyer, seller or investor) may rely on a Deliverable, and T&T owes no duty of care to any third party, unless T&T has expressly agreed in a signed reliance letter. The Customer will inform any person to whom it discloses a Deliverable of this restriction.
B14.4 No public use. The Customer may not publish a Deliverable, use it in marketing, or state or imply that T&T has "approved", "certified" or "guaranteed" a Counterparty, a product or a transaction.
B14.5 Filings. Documents filed with an agency or registry in the Customer's name (for example articles of organization or an FDA registration) belong to the Customer for all purposes, subject to the public nature of the registry.

B15. Intellectual property

B15.1 Customer materials. The Customer retains all rights in the information, documents and materials it provides. It grants T&T a non-exclusive license to use them for the purpose of performing the Engagement and complying with T&T's legal obligations.
B15.2 T&T materials. T&T retains all rights in its methodologies, checklists, templates, know-how, software, databases, models and the general skill and knowledge acquired in performing the Services, including any that are used in or improved through an Engagement, and in the content of the Site. Nothing in these Terms transfers to the Customer any intellectual property right other than the license in Section B14.1.
B15.3 Third-party materials. Deliverables may contain extracts from public registries, official lists or licensed databases. Those extracts remain subject to the rights and terms of their owners.

B16. Confidentiality

B16.1 Definition. "Confidential Information" means all non-public information disclosed by one party (the "Discloser") to the other (the "Recipient") in connection with an Engagement or a request for one, in any form, that is marked as confidential or that a reasonable business person would understand to be confidential, including the existence and terms of a transaction, Counterparty information, Deliverables and prices offered in a Quote.
B16.2 Obligations. The Recipient will (a) use Confidential Information only to perform or receive the Services and to exercise its rights under the Engagement, (b) not disclose it except to its members, employees, subcontractors and professional advisers who need to know it and are bound by obligations of confidentiality at least as protective as this Section, and (c) protect it with at least the degree of care it uses for its own confidential information, and not less than reasonable care.
B16.3 Exceptions. The obligations of Section B16.2 do not apply to information that the Recipient can show (a) is or becomes publicly available without breach of these Terms, (b) was lawfully known to the Recipient before disclosure without an obligation of confidentiality, (c) is lawfully received from a third party without an obligation of confidentiality, or (d) is independently developed without use of the Confidential Information.
B16.4 Compelled disclosure. The Recipient may disclose Confidential Information to the extent required by law, regulation, court order or a competent authority (including reporting obligations under Applicable Sanctions Laws), provided that, where lawful, it gives the Discloser prompt notice and cooperates with any effort to limit the disclosure.
B16.5 Duration. The obligations of this Section apply during each Engagement and for five (5) years after its end. For trade secrets within the meaning of the Florida Uniform Trade Secrets Act (Fla. Stat. Chapter 688), they continue for as long as the information remains a trade secret.
B16.6 Return or deletion. On written request after the end of an Engagement, the Recipient will delete or return the Discloser's Confidential Information, except copies that it must keep by law, copies kept in its records for the defense of claims, and copies in automatic backups, which remain subject to this Section until deleted in the ordinary course.
B16.7 Defend Trade Secrets Act notice. Under 18 U.S.C. §1833(b), an individual is not held criminally or civilly liable under any federal or state trade secret law for the disclosure of a trade secret made in confidence to a government official or an attorney solely for the purpose of reporting or investigating a suspected violation of law, or in a complaint or other document filed under seal in a lawsuit.

B17. Data protection

B17.1 Privacy Policy. T&T processes personal data of the Customer's Representative and contacts as described in the Privacy Policy available on the Site, which identifies T&T Consulting Business, LLC and Tudor & Tudor, LLC as joint controllers under a written arrangement between the two companies.
B17.2 Counterparty and third-party data: independent controller. When T&T processes personal data of Counterparties and of other third parties (for example beneficial owners, directors or signatories) in order to perform a due diligence, sanctions screening, verification or commodity Service, T&T acts as an independent controller, because it determines the sources consulted, the verification methodology, the content of its Deliverables and the retention of its records to meet its own legal obligations. T&T processes that data in accordance with the Privacy Policy. The Customer, for its part, is an independent controller for the data it provides to T&T and for its own use of the Deliverables, and is responsible for having a lawful basis and for informing the data subjects where the law requires it.
B17.3 Processor role by exception. Where, exceptionally, T&T processes personal data only on the documented instructions of the Customer and for the Customer's purposes (for example the implementation of a compliance program using the Customer's employee or customer data), the parties will sign T&T's standard data processing agreement, which meets the requirements of Article 28 of Regulation (EU) 2016/679 (GDPR) where that Regulation applies, before T&T processes such data. The standard data processing agreement is provided on request sent to legal@tudorsgroup.com.
B17.4 No model training and human review. T&T uses a language model hosted on its own server to classify requests and write a one-line summary for internal triage. The model does not take decisions with legal or similarly significant effects on any person; every request is read by a person; and data received from the Customer is not used to train models.
B17.5 Cooperation. Each party will provide reasonable cooperation to the other to respond to data subject requests and to notify personal data breaches where the law requires it.

B18. Limited warranty

B18.1 T&T warrants that it will perform the Services with the reasonable skill, care and diligence of a competent business consultant providing similar services, and in accordance with the description of the Service on the Service Page or in the Quote.
B18.2 The Customer's sole and exclusive remedy for a breach of Section B18.1, notified in writing within thirty (30) days of delivery of the Deliverable concerned, is the re-performance of the deficient part of the Service at no charge, or, if re-performance is not possible or does not cure the breach, a refund of the Fees paid for the deficient part.

B19. Disclaimer of other warranties

EXCEPT AS EXPRESSLY STATED IN SECTION B18.1, THE SERVICES AND DELIVERABLES ARE PROVIDED WITHOUT ANY OTHER WARRANTY OR REPRESENTATION, EXPRESS, IMPLIED OR STATUTORY. TO THE FULLEST EXTENT PERMITTED BY LAW, T&T DISCLAIMS ALL IMPLIED WARRANTIES, INCLUDING THE IMPLIED WARRANTY OF MERCHANTABILITY, THE IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, AND ANY WARRANTY OF TITLE, NON-INFRINGEMENT, ACCURACY OR COMPLETENESS OF INFORMATION OBTAINED FROM PUBLIC REGISTRIES, OFFICIAL LISTS, THIRD-PARTY DATABASES OR COUNTERPARTIES, AND ANY WARRANTY ARISING FROM A COURSE OF DEALING OR USAGE OF TRADE. T&T DOES NOT WARRANT THAT ANY COUNTERPARTY WILL PERFORM, THAT ANY TRANSACTION WILL BE COMPLETED OR PROFITABLE, OR THAT ANY AGENCY WILL GRANT ANY REGISTRATION, PERMIT OR LICENSE.

B20. Limitation of liability

B20.1 Exclusion of indirect damages. TO THE FULLEST EXTENT PERMITTED BY LAW, T&T SHALL NOT BE LIABLE, WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), BREACH OF STATUTORY DUTY OR OTHERWISE, FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, BUSINESS, CONTRACTS, OPPORTUNITY, GOODWILL OR DATA, OR FOR ANY LOSS CAUSED BY THE ACTS, OMISSIONS, FRAUD OR INSOLVENCY OF A COUNTERPARTY OR OTHER THIRD PARTY, EVEN IF T&T WAS ADVISED OF THE POSSIBILITY OF SUCH LOSS.
B20.2 Cap. TO THE FULLEST EXTENT PERMITTED BY LAW, T&T'S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR IN CONNECTION WITH AN ENGAGEMENT, UNDER ANY THEORY OF LIABILITY, IS LIMITED TO THE FEES ACTUALLY PAID BY THE CUSTOMER FOR THAT ENGAGEMENT. FOR ANNUAL SERVICES, THE CAP IS THE FEES PAID FOR THE ANNUAL TERM IN WHICH THE EVENT GIVING RISE TO THE CLAIM OCCURRED. THIRD-PARTY FEES ARE NOT COUNTED IN THE CAP.
B20.3 Exceptions. Nothing in these Terms excludes or limits liability (a) for fraud or fraudulent misrepresentation, (b) for intentional misconduct, or (c) that cannot be excluded or limited under applicable law.
B20.4 Basis of the bargain. The Customer acknowledges that the Fees reflect the allocation of risk in this Section B20, that it has had the opportunity to review these Terms, and that T&T would not provide the Services at these Fees without these limitations.
B20.5 Customer obligations not limited. This Section B20 does not limit the Customer's obligation to pay Fees and Third-Party Fees, or its obligations under Sections B7, B16 and B21.

B21. Indemnification by the Customer

The Customer shall defend, indemnify and hold harmless T&T, its members, managers, employees and subcontractors from and against all claims, losses, liabilities, penalties, fines, costs and expenses (including reasonable attorneys' fees) arising out of or relating to:
(a) any false, inaccurate or incomplete information or document provided by or for the Customer;
(b) the Customer's lack of right to provide third-party information or personal data to T&T;
(c) a breach by the Customer of Sections B7, B12, B14 or B16;
(d) any agency fee, penalty or charge imposed on T&T as a result of acting for the Customer, including FDA reinspection fees assessed to T&T as U.S. Agent (Section C4.4) and any liability arising from T&T's role as FSVP importer caused by the Customer's non-compliance (Section C4.5);
(e) any claim by a third party (including a Counterparty) relating to the Customer's use of a Deliverable; or
(f) the Customer's continuing obligations as owner of a company, facility or permit (Section C5).
T&T will give the Customer prompt notice of any claim, allow the Customer reasonable control of the defense (except where the claim involves an agency proceeding against T&T, which T&T controls), and cooperate at the Customer's expense.

B22. Non-circumvention

Non-circumvention in relation to commodity transactions and introductions is governed by the non-circumvention and non-disclosure agreement (NCNDA) signed between the parties for the transaction concerned. Section C7 applies.

B23. Term and termination

B23.1 Each Engagement ends when the Service has been performed in full or, for annual Services, at the end of the annual term.
B23.2 Either party may terminate an Engagement by written notice if the other party commits a material breach and fails to cure it within fifteen (15) days of a written notice describing it.
B23.3 T&T may terminate under Section B7.3 and Section B8.8(d) as provided there.
B23.4 Termination does not affect rights accrued before termination. Refunds on termination follow Sections B7.4, B9 and B9.6.

B24. Force majeure

Neither party is liable for any delay or failure to perform (other than payment obligations) caused by events beyond its reasonable control, including acts of God, natural disasters, epidemic, war, terrorism, civil unrest, government action (including new sanctions, embargoes or export restrictions), lapse of appropriations or shutdown of government agencies, failures of public utilities, telecommunications or internet infrastructure, cyberattacks not caused by the affected party's negligence, and outages of third-party platforms on which the Services depend. The affected party will notify the other promptly and use reasonable efforts to mitigate. If the event continues for more than sixty (60) days, either party may terminate the affected Engagement by written notice; T&T then refunds Fees for work not yet performed.

B25. Assignment

The Customer may not assign or transfer any Engagement or right under it without T&T's prior written consent. T&T may assign an Engagement to a company of the T&T group or to a successor of its business by notice to the Customer, provided that the assignment does not reduce the Customer's rights.

B26. Subcontracting

T&T may use subcontractors, including companies of the T&T group, registered agent providers, filing agents, translators, local consultants, data providers, and duly licensed investigators and law firms engaged under Section B26A, to perform parts of the Services. T&T remains responsible to the Customer for the performance of its subcontractors as for its own, within the limits of Section B20. T&T is not responsible for third parties selected or required by the Customer, nor for agencies, registries, banks or Counterparties.

B26A. Activities subject to licensing

B26A.1 Where any Engagement, under any Service, requires activities that, under the law of the place where they are performed, may only be carried out by a licensed professional (for example private investigation under Chapter 493 of the Florida Statutes, or the practice of law), T&T will not perform those activities itself. They will be carried out by a duly licensed professional engaged for that Engagement, whose participation, scope and cost T&T will inform the Customer of in writing before the work begins. The Customer's acceptance of that scope forms part of the Quote.
B26A.2 In particular, where a Customer needs a legal conclusion on whether a transaction is permitted under Applicable Sanctions Laws or any other law, that conclusion will be given in writing by a lawyer licensed in the relevant jurisdiction and engaged under Section B26A.1. T&T's own deliverables are business and compliance analysis and are not legal opinions.

B27. Notices and electronic communications

B27.1 Notices to T&T must be sent by email to legal@tudorsgroup.com. Notices to the Customer may be sent to the email address used for the Order or the Quote, or to any other address the Customer notifies in writing.
B27.2 A notice sent by email is deemed received on the day it is sent if sent before 17:00 in the recipient's time zone on a Business Day, and otherwise on the next Business Day, unless the sender receives an automated message indicating non-delivery.
B27.3 Operational messages (confirmations, reminders, requests for information) may be sent from automated tudorsgroup.com addresses.
B27.4 Beware of impersonation. T&T sends notices only from addresses on the tudorsgroup.com domain. T&T will never change its payment details by email alone. Any request to pay T&T into a new account must be confirmed through a separate channel before payment.

B28. Governing law

These Terms, every Engagement and any dispute or claim (contractual or non-contractual) arising out of or in connection with them are governed by the laws of the State of Florida and the federal laws of the United States applicable in Florida, without regard to conflict-of-laws principles that would apply the law of another jurisdiction. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

B29. Dispute resolution

B29.1 Good-faith negotiation. Before commencing an arbitration or a court action (other than an application under Section B29.5(b)), the claiming party sends the other party a written notice describing the claim, the facts on which it is based and the relief sought. The parties' authorized representatives then negotiate in good faith to resolve the dispute for thirty (30) days from receipt of that notice. If the dispute is not resolved within that period, either party may commence arbitration under Section B29.2.
B29.2 Arbitration. Any controversy or claim arising out of or relating to these Terms, any Engagement, the Services or the Site, or the breach thereof, including any question regarding their existence, validity, interpretation, performance or termination and any non-contractual claim, shall be determined by arbitration administered by the International Centre for Dispute Resolution in accordance with its International Arbitration Rules, except as provided in Section B29.5.
B29.3 Terms of the arbitration.
(a) Number of arbitrators. The tribunal consists of one sole arbitrator, appointed in accordance with the ICDR Rules.
(b) Seat. The seat (legal place) of arbitration is Miami, Florida, United States. Hearings may be held by video conference where the arbitrator so decides.
(c) Language. The language of the arbitration is English. Documents in Spanish or Portuguese may be submitted without translation unless the arbitrator orders otherwise.
(d) Expedited procedure. The International Expedited Procedures of the ICDR Rules apply in every case to which those Rules make them applicable, which, under Article 1(4) of the ICDR Rules in force on the date of these Terms, is any case in which no disclosed claim or counterclaim exceeds USD 500,000, exclusive of interest and the costs of arbitration. The parties may also agree in writing to apply them to any other case.
(e) Award. The award is final and binding on the parties, who undertake to carry it out without delay. Judgment on the award may be entered by any court having jurisdiction. The award may be recognized and enforced under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 10 June 1958) and Chapter 2 of the Federal Arbitration Act (9 U.S.C. §§201 to 208).
(f) Law of the arbitration agreement. This arbitration agreement is governed by the Federal Arbitration Act (9 U.S.C. §1 et seq.) and, to the extent consistent with it, by the Florida International Commercial Arbitration Act (Chapter 684 of the Florida Statutes).
(g) Confidentiality. The existence, content and outcome of the arbitration are Confidential Information under Section B16, except to the extent disclosure is necessary to enforce or challenge the award or is required by law.
(h) Costs. The costs of the arbitration, including the administrative fees of the ICDR, the compensation of the arbitrator and the parties' reasonable legal costs, are allocated by the arbitrator in the award in accordance with the ICDR Rules.
B29.4 Emergency relief. Either party may apply for emergency measures of protection under the ICDR Rules.
B29.5 Exceptions: courts of Miami-Dade County. Notwithstanding Section B29.2:
(a) T&T may bring an action to recover unpaid Fees, Third-Party Fees, interest under Section B8.7 and amounts owed under Section B8.8(e), in the courts listed in Section B29.6; and
(b) either party may apply to the courts listed in Section B29.6 for interim, provisional or conservatory measures, including injunctive relief to protect Confidential Information or intellectual property, before or during an arbitration. Such an application is not incompatible with, and does not waive, the agreement to arbitrate.
B29.6 Courts and submission to jurisdiction. For the purposes of Section B29.5, and for any action to compel arbitration or to confirm, vacate, recognize or enforce an award, the state courts of Florida sitting in Miami-Dade County (Eleventh Judicial Circuit) and the United States District Court for the Southern District of Florida, Miami Division, have jurisdiction. Each party irrevocably submits to the personal jurisdiction of those courts for those purposes and waives any objection based on venue or inconvenient forum. This Section does not prevent the enforcement of an award or judgment in any other jurisdiction.
B29.7 If the arbitration agreement does not apply. If, for any dispute, the agreement to arbitrate in Section B29.2 is held invalid, inoperative or incapable of being performed, that dispute is subject to the exclusive jurisdiction of the courts listed in Section B29.6.

B30. WAIVER OF JURY TRIAL

DISPUTES SUBJECT TO SECTION B29.2 ARE DECIDED BY AN ARBITRATOR AND NOT BY A JUDGE OR JURY. IN ADDITION, TO THE FULLEST EXTENT PERMITTED BY LAW, EACH PARTY KNOWINGLY, VOLUNTARILY AND INTENTIONALLY WAIVES ANY RIGHT IT MAY HAVE TO A TRIAL BY JURY IN ANY COURT ACTION, PROCEEDING OR COUNTERCLAIM ARISING OUT OF OR RELATING TO THESE TERMS, ANY ENGAGEMENT, THE SERVICES OR THE SITE, INCLUDING ANY ACTION UNDER SECTIONS B29.5 TO B29.7. EACH PARTY ACKNOWLEDGES THAT THIS WAIVER IS A MATERIAL INDUCEMENT FOR THE OTHER PARTY TO ENTER INTO THE ENGAGEMENT.

B31. WAIVER OF CLASS, COLLECTIVE AND CONSOLIDATED PROCEEDINGS

TO THE FULLEST EXTENT PERMITTED BY LAW, EACH PARTY AGREES THAT ANY CLAIM ARISING OUT OF OR RELATING TO THESE TERMS OR ANY ENGAGEMENT WILL BE BROUGHT ONLY IN ITS INDIVIDUAL CAPACITY, IN ARBITRATION OR IN COURT, AND NOT AS A CLAIMANT, PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR HAS NO AUTHORITY TO CONDUCT A CLASS OR COLLECTIVE ARBITRATION, OR TO CONSOLIDATE OR JOIN THE CLAIMS OF OTHER CUSTOMERS OR THIRD PARTIES WITH THE ARBITRATION BETWEEN T&T AND THE CUSTOMER, WITHOUT THE WRITTEN CONSENT OF ALL PARTIES CONCERNED.

B32. Time limit for claims

B32.1 Any claim against T&T arising out of an Engagement must be notified to T&T in writing under Section B29.1 promptly after the Customer becomes aware of the facts giving rise to it.
B32.2 Actions are subject to the limitation periods of Florida law. The parties acknowledge that, under Fla. Stat. §95.03, a contractual provision fixing a period for bringing an action shorter than the applicable statutory limitation period is void; nothing in these Terms is intended to shorten that period.

B33. Language

These Terms are drafted in English. T&T may publish translations. In case of any difference between the English version and a translation, the English version prevails. Communications in an Engagement may be in English, Spanish or Portuguese. Deliverables are issued in English unless the Service Page or the Quote provides otherwise.

B34. Changes to these Terms

B34.1 T&T may amend these Terms by publishing a new version on the Site with a new "Last updated" date and version number.
B34.2 Each Engagement is governed by the version in force at its Payment Time or, for Quotes, on the date the Quote was accepted. For annual Services, each new annual term ordered by the Customer is governed by the version in force at the Payment Time of that term.
B34.3 Part A, as amended, applies to the use of the Site from the date of publication.

B35. General provisions

B35.1 Entire agreement. Each Engagement, consisting of the documents listed in Section B1.1, constitutes the entire agreement between the parties on its subject matter and supersedes all prior proposals, statements and understandings. The Customer acknowledges that it has not relied on any statement not set out in those documents. Nothing in this Section limits liability for fraud.
B35.2 Waiver. No failure or delay by a party in exercising a right operates as a waiver of it. A waiver is effective only if made in writing, and applies only to the specific instance.
B35.3 Severability. If any provision of these Terms is held invalid or unenforceable, it is enforced to the maximum extent permitted and, to the extent it cannot be, severed; the remaining provisions remain in full force.
B35.4 Survival. Sections B7.4, B8, B9, B14, B15, B16, B17, B19, B20, B21, B22, B28 to B33 and B35, and any other provision that by its nature should survive, survive the end of an Engagement.
B35.5 Independent contractors. The parties are independent contractors. Nothing in an Engagement creates a partnership, joint venture, agency, fiduciary or employment relationship, except where T&T is expressly appointed as an agent for a defined regulatory purpose (Sections C4 and C5), and then only for that purpose.
B35.6 No third-party beneficiaries. No person other than the parties has any right to enforce an Engagement.
B35.7 Records. T&T's electronic records of acceptances, payments, communications and delivery are admissible as evidence and, in the absence of manifest error, are prima facie evidence of the facts they record.

Part C · Conditions of each Service

Each Section of Part C applies only to the Service it names, in addition to Parts A and B. Each Service Page links to its Section using the anchor shown.

C1. Consultations

C1.0 This Section reproduces, without changes, Section 3A of the conditions of Consultations, in force since 23 September 2026.

3A.1 Consultations are booked through this site and paid in full at the time of booking. The rate for each duration is shown before payment.
3A.2 If you cancel more than two hours before the appointment, the amount paid is refunded less a 5% administrative fee.
3A.3 If you cancel within two hours of the appointment, the amount paid is not refunded. Instead, you may change the date of the appointment once, keeping the amount you already paid. The date can be changed one time only. This right expires three months after the date of the original appointment, and the new date must fall within those three months.
3A.4 If you do not attend an appointment whose date has already been changed, the amount is not refunded and the date cannot be changed again.
3A.5 We send a reminder before each appointment stating the time until which you can still cancel with a refund.
3A.6 If you go on to contract one of our services, the amount paid for the consultation is credited against the total of that service, provided the service is USD 1,000 or more, for three months from the date of the consultation.
3A.7 Times are shown in your own time zone. The time confirmed in writing is the time that applies.

C2. Due diligence: counterparty and transaction reports

C2.1 Scope.
(a) Counterparty report (fixed price shown on the Service Page): a written commercial compliance analysis of a company named by the Customer, based exclusively on the documents provided by the Customer, public registries and official lists (including sanctions lists), stating what could be verified and what could not. The counterparty report does not include interviews, surveillance, or the gathering of non-public information.
(b) Transaction report (fixed price shown on the Service Page): a written report on a proposed transaction, covering the parties, the documents and the commercial structure described by the Customer, and identifying inconsistencies and risk indicators.
(c) Mandate: an ongoing verification or representation mandate, priced and scoped in a Quote and, where required, a signed mandate.
C2.1A Licensed activities. Section B26A applies.
C2.2 Not included. Unless a Quote states otherwise, a report does not include: site visits or physical inspection of goods; laboratory analysis; verification of bank instruments with the issuing bank; legal opinions on the validity or enforceability of contracts; credit ratings; tax analysis; or ongoing monitoring after delivery.
C2.3 Information to be provided. The Customer provides: the full legal name and country of the Counterparty; any registration or tax number known; the documents received from the Counterparty (offers, letters of intent, corporate documents, bank documents, mandates); a description of the transaction (product, volume, Incoterms, origin, price, frequency); and any other information requested by T&T.
C2.4 Deadline for the counterparty report. T&T delivers the counterparty report within three (3) Business Days from the Payment Time, as stated on the Service Page. This deadline is suspended under Section B10.2 while any information or document requested from the Customer is missing. The transaction report is delivered within the period stated on the Service Page or in the Quote.
C2.5 Lawful source of third-party information. The Customer warrants that it obtained the Counterparty documents and information lawfully and may share them with T&T for the purpose of verification (Section B12(b)).
C2.6 Full refund if T&T introduced the Counterparty. If the Counterparty that the Customer asks T&T to verify was introduced to the Customer by T&T, T&T refunds the full Fees paid for the report, as stated on the Service Page. The refund is made automatically as soon as T&T detects that it introduced the Counterparty, or on the Customer's request, whichever occurs first. The introduction must be documented in T&T's written communications with the Customer. The refund does not affect the delivery of the report.
C2.7 Late delivery. If T&T delivers the counterparty report after the deadline of Section C2.4 (taking into account any suspension under Section B10.2), T&T refunds thirty percent (30%) of the Fees paid for that report, as stated on the Service Page. This is the Customer's sole remedy for late delivery.
C2.8 Nature of a report. A report states facts verified or not verified at its date. It is not a guarantee of performance, solvency or honesty of the Counterparty, a credit rating, an audit, or legal advice on any contract (Sections B6 and B19). A report that finds no adverse information does not mean that none exists.
C2.9 Contact with the Counterparty. T&T does not contact the Counterparty without the Customer's prior consent, except to verify publicly listed contact details without disclosing the Customer's identity.

C3. Transaction phases (ALCA)

C3.1 Scope. The ALCA phases are a structured, multi-stage accompaniment of a transaction, scoped and priced in a Quote. The Service Page shows prices "from" a minimum amount for each phase.
C3.2 Quote required. No ALCA phase starts until the Customer accepts a Quote that defines the phase's objectives, deliverables, assumptions, exclusions, timeline and price, and any advance payment is received.
C3.3 Phase gates. Each phase ends with a Deliverable. The next phase starts only on written acceptance by the Customer of the Quote for that phase. Either party may decide not to proceed to the next phase without liability.
C3.4 Changes of scope. Any change to the scope of a phase requires a written change agreed by both parties, with any adjustment of price and timeline.
C3.5 Exclusions. ALCA phases do not include legal representation, the holding or transfer of funds, escrow, financing or the guarantee of any transaction. The provisions of Section C2.2 apply.
C3.6 Cancellation. Section B9 applies to each phase from the Payment Time of that phase, unless the Quote provides for staged payments, in which case the Quote prevails.

C4. FDA services

C4.1 Scope. The FDA services, as described on each Service Page, are: food facility registration; U.S. Agent service; biennial registration renewal; prior notice of imported food (per shipment); FSVP agent service; label review (per product reference); and support with import alerts (by Consultation).
C4.2 Registration is free with the FDA. The FDA does not charge a fee to register a food facility under Section 415 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. §350d) and 21 C.F.R. Part 1, Subpart H. T&T's Fees are for preparing, filing and managing the registration, not for the registration itself. Beware of anyone claiming that an FDA registration "costs" a government fee.
C4.3 Biennial renewal. Food facility registrations must be renewed between 1 October and 31 December of each even-numbered year (21 C.F.R. §1.230(b)). T&T files the renewal only if the Customer has ordered the renewal Service and provided the information requested. A registration that is not renewed is considered expired by the FDA.
C4.4 U.S. Agent.
(a) A foreign food facility must designate a U.S. Agent residing or maintaining a place of business in the United States (21 C.F.R. §§1.227 and 1.232). T&T acts as U.S. Agent for the facility named in the Order, for annual terms.
(b) The FDA treats communications to the U.S. Agent as communications to the facility. T&T will forward to the Customer, within two (2) Business Days of receipt, any FDA communication received as U.S. Agent. The Customer must keep its email contact current and respond to FDA requests.
(c) Under Section 743(a)(1)(A) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. §379j-31(a)(1)(A)), FDA is authorized to assess and collect fees for reinspection-related costs from the U.S. agent of each foreign facility subject to a reinspection. FDA publishes the applicable rates for each fiscal year in the Federal Register. Any such fee assessed to T&T for the Customer's facility is a Third-Party Fee payable by the Customer, which must reimburse T&T within ten (10) Business Days of request, under Section B21(d).
(d) If the Customer's annual term ends without renewal, or if T&T terminates the Service, T&T will cease to act as U.S. Agent and may inform the FDA. The Customer must designate a new U.S. Agent and update its registration within sixty (60) days as required by 21 C.F.R. §1.234.
C4.5 FSVP agent.
(a) The Foreign Supplier Verification Programs rule (21 C.F.R. §§1.500 to 1.514) applies to the "FSVP importer". Where there is no U.S. owner or consignee at the time of entry, the importer is the U.S. agent or representative of the foreign owner or consignee, confirmed in a signed statement of consent (21 C.F.R. §1.500).
(b) Before T&T acts in that capacity, the parties sign a specific FSVP agreement defining the foods and foreign suppliers covered, the documents the Customer must provide (including hazard analysis, supplier evaluation and verification records), and the Customer's obligation to keep T&T informed. T&T does not act as FSVP importer until that agreement is signed. The Service Page price is "from" a minimum; the final price depends on the number of foods and suppliers.
(c) T&T may refuse to act, or to continue to act, as FSVP importer for any food or supplier for which it does not receive adequate documentation.
C4.6 Prior notice. Prior notice is required for food imported or offered for import into the United States (21 C.F.R. §§1.276 to 1.285). The Customer must provide complete shipment data within the time stated on the Service Page, before the deadline applicable to the mode of transport. T&T is not responsible for refusal or holding of a shipment caused by late or inaccurate data.
C4.7 Label review. A label review assesses a label against the federal labeling requirements identified on the Service Page (including 21 C.F.R. Part 101) at its date. It does not cover state-specific requirements, product claims not submitted to T&T, or later changes to the label or the law.
C4.8 Import alerts. Support with import alerts is provided by Consultation (Section C1). Removal from an import alert is decided only by the FDA.
C4.9 Annual Services: no automatic renewal. U.S. Agent and FSVP agent are annual Services. They do not renew automatically. T&T will send a reminder to the Customer thirty (30) days before the end of each annual term. If the Customer does not order and pay a new annual term before the end of the current term, the Service ends at the end of the term and Section C4.4(d) applies. Nothing is charged to the Customer without a new Order.
C4.10 No guarantee. The FDA decides on registrations, admissibility, inspections, detentions, refusals and import alerts (Section B11).

C5. Company formation and U.S. permits

C5.1 Scope. As described on each Service Page: formation of a U.S. limited liability company in the State of Florida or the State of Delaware, as chosen by the Customer; obtaining an Employer Identification Number (EIN) from the IRS; registered agent service; annual maintenance; support with USDA plant and animal import permits; and support with TTB permits (by Consultation).
C5.2 State fees. The Fees do not include state filing fees, franchise taxes, annual report fees or other state charges, which depend on the State chosen and are shown separately at checkout or in the Quote at cost. In Florida these include the fees set by Fla. Stat. §605.0213 for filing articles of organization, the designation of a registered agent and the annual report; in Delaware they include the filing fees of the Division of Corporations and the annual limited liability company tax under 6 Del. C. §18-1107. The amounts are those in force on the date of each filing, and are shown to the Customer before payment. Once filed, state fees are not refundable (Section B9.4).
C5.3 Scrivener role. In company formation T&T prepares and files documents on the basis of the Customer's instructions. T&T does not advise on the choice of entity, the operating agreement's legal effects, tax classification or the Customer's legal position (Section B6.2). The Customer is responsible for the content of documents filed in its name.
C5.4 EIN. The IRS issues the EIN. Where the responsible party does not have a U.S. taxpayer identification number, the application may require filing Form SS-4 by fax or mail and processing times are set by the IRS. The Customer authorizes T&T as third-party designee for the application only.
C5.5 Registered agent. T&T, or a registered agent provider acting as its subcontractor, acts as registered agent for annual terms, accepts service of process and official notices at the registered office, and forwards them to the Customer promptly, normally within two (2) Business Days. The Customer must keep its contact details current. On termination of the Service, the registered agent may resign under the procedure of the applicable State law (in Florida, Fla. Stat. §605.0115; in Delaware, 6 Del. C. §18-104), and the Customer must appoint a new registered agent.
C5.6 Annual maintenance. Annual maintenance covers the filing of the annual report or equivalent in the State of formation, as described on the Service Page. State fees are additional (Section C5.2). In Florida the annual report must be filed between 1 January and 1 May of each year (Fla. Stat. §605.0212), and a late fee set by Fla. Stat. §605.0213 applies to reports filed after 1 May; a company that does not file may be administratively dissolved. In Delaware the annual tax is payable on or before 1 June of each year. T&T files only on receipt of the Customer's payment of the annual maintenance Fees and State fees.
C5.7 Continuing obligations of the Customer. After formation, the Customer and its owners remain responsible for all continuing obligations of the company, including: federal and state tax returns and information returns (including, for a single-member LLC wholly owned by a foreign person and disregarded for income tax purposes, Form 5472 attached to a pro forma Form 1120, under 26 U.S.C. §6038A, 26 C.F.R. §1.6038A-1 and 26 C.F.R. §301.7701-2(c)(2)(vi)); beneficial ownership information reporting to the Financial Crimes Enforcement Network (FinCEN) where 31 C.F.R. §1010.380 applies (under that section as amended in 2025 and 2026, companies formed in the United States are exempt, and the obligation remains for entities formed under foreign law that register to do business in a State); licenses and local registrations; keeping records; and maintaining good standing. These obligations are not part of the Services unless expressly ordered.
C5.8 USDA and TTB permits. USDA permits (including those issued by the Animal and Plant Health Inspection Service, APHIS) and TTB permits (including basic permits under the Federal Alcohol Administration Act, 27 U.S.C. §203) are granted or refused by those agencies. T&T prepares and files applications on the Customer's information and instructions.
C5.9 Annual Services: no automatic renewal. Registered agent and annual maintenance are annual Services. They do not renew automatically. T&T sends a reminder thirty (30) days before the end of each annual term. If the Customer does not order and pay a new annual term before the end of the current term, the Service ends at the end of the term and Section C5.5 applies to the registered agent. Nothing is charged to the Customer without a new Order.

C6. OFAC and sanctions services

C6.1 Scope. As described on each Service Page: (a) a written sanctions risk assessment of a proposed transaction, Counterparty or activity; (b) the design of a sanctions compliance program; and (c) support in preparing and submitting an application for a specific license to OFAC.
C6.2 Basis of a sanctions risk assessment. A sanctions risk assessment is a business and compliance analysis that identifies sanctions risk indicators by applying Applicable Sanctions Laws as in force, and the sanctions lists as published, on its date, to the facts provided by the Customer. Sanctions change frequently and without notice; a sanctions risk assessment does not cover later changes, and it is not a legal opinion (Section B6.2). Where the Customer needs a legal conclusion, Section B26A.2 applies.
C6.3 Compliance program. A compliance program is designed with reference to OFAC's "A Framework for OFAC Compliance Commitments" (May 2019). Its effectiveness depends on its implementation by the Customer, which remains responsible for its compliance with Applicable Sanctions Laws.
C6.4 Specific licenses. Applications for specific licenses are submitted under the procedures of 31 C.F.R. Part 501, including §501.801. OFAC decides whether to grant a license, its conditions and its timing, which may take many months. T&T does not guarantee that a license will be granted or when (Section B11). The Customer must not engage in the licensed activity before a license is issued, and must comply with its conditions and reporting requirements.
C6.5 Price range. The price of a license application depends on its complexity and is set in a Quote within the range shown on the Service Page.
C6.6 Truthfulness. Applications to OFAC must be complete and accurate. The Customer is solely responsible for the truthfulness of the facts it provides. T&T will not submit an application that it believes to be false or misleading.
C6.7 Records. The Customer is responsible for keeping its own records of transactions subject to Applicable Sanctions Laws for the period required by law (31 C.F.R. §501.601, currently ten (10) years).

C7. Commodities

C7.1 Offers are indicative. Any offer of commodities shown on the Site or communicated by T&T (including diesel EN590, fuel oil D6, Jet A1 and ICUMSA 45 sugar) is indicative and non-binding, and is subject to availability, verification of both parties, and the signature of a written sale and purchase agreement ("SPA"). No contract for the sale of goods is formed through the Site.
C7.2 Process. A transaction proceeds only after (a) KYC verification of both buyer and seller under Section B7, (b) where applicable, the signature of a non-circumvention and non-disclosure agreement ("NCNDA"), and (c) the signature of an SPA that sets out the product specification, quantity and tolerance, price and price basis, Incoterms 2020 rule and named place, inspection and quality determination, documents, payment instrument, title and risk, force majeure, governing law and dispute resolution.
C7.3 Incoterms. References to delivery terms are to the Incoterms 2020 rules published by the International Chamber of Commerce (ICC), which owns the Incoterms trademark. Incoterms define the allocation of costs, risks and delivery obligations; they do not regulate transfer of title, payment or breach, which are governed by the SPA.
C7.4 T&T NEVER ASKS FOR ADVANCE PAYMENTS. T&T never asks a buyer or seller for an advance payment, fee, commission, deposit, "procedure fee", "document fee" or similar payment in order to open, reserve or advance a commodity transaction. Anyone who asks for such a payment in T&T's name is not acting for T&T. Do not pay, and report it to legal@tudorsgroup.com. This does not concern the Fees for verification Services ordered by a Customer through the Site under Section C2, which are paid only through the Site's Stripe Checkout or a Quote issued from a tudorsgroup.com address.
C7.5 Verification of third-party transactions. Where a Customer asks T&T to verify a commodity transaction offered by a third party, Section C2 applies.
C7.6 Non-circumvention. Introductions of buyers, sellers, intermediaries or facilities by T&T are subject to the NCNDA signed for the transaction. Where no NCNDA has been signed, the Customer undertakes, for twenty-four (24) months from an introduction documented in writing by T&T, not to deal directly or indirectly with the introduced party in relation to the same product without T&T's written consent. Where an NCNDA has been signed, its terms apply instead of this Section.
C7.7 No role as principal, broker or escrow. Unless an SPA names T&T as a party, T&T does not act as buyer, seller, guarantor or escrow agent, and does not hold funds or title documents.
C7.8 Precedence. For any transaction, the SPA prevails over these Terms in all matters it regulates (Section B1.1(a)).

C8. Food and beverage trade (Adriatic)

C8.1 Requests sent through the Adriatic pages of the Site are requests for information or quotation. They do not form a contract of sale.
C8.2 Food and beverage products are sold by Tudor Adriatic d.o.o. (Split, Croatia), a company of the T&T group, under its own conditions of sale and the law they designate. Requests sent through the Adriatic pages are received by Tudor Adriatic d.o.o. for that purpose. Any contract of sale is concluded between the buyer and Tudor Adriatic d.o.o.; T&T Consulting Business, LLC is not a party to it and assumes no obligation in respect of the goods. These Terms apply only to the use of the Site to send the request.
C8.3 Any sale of goods is subject to a written order confirmation or contract that specifies product, quantity, price, Incoterms 2020 rule, delivery, food safety documentation and payment terms.

C9. Careers

C9.1 Submitting an application through the Site does not create any employment, contractor or other relationship, nor any obligation to make an offer.
C9.2 The candidate confirms that the information and CV submitted are accurate and his or her own, and that any third-party data in the CV (for example references) is shared lawfully.
C9.3 Applications are kept for twelve (12) months from the close of the selection process concerned, as described in the Privacy Policy, and then deleted.
C9.4 Applying through the Site is free of charge. Any request for payment made in T&T's name in connection with a job offer should be reported to legal@tudorsgroup.com before any payment is made.

C10. Site assistant

C10.1 The Site assistant ("Ask a question") answers from a fixed set of predefined questions and answers. It does not run an artificial intelligence model in the browser and does not generate answers about the user's specific case.
C10.2 Answers of the assistant are general information under Section A2. They are not advice, do not create an Engagement and do not bind T&T as to price, availability or the outcome of any Service.
C10.3 If the user submits a question with an email address, a person at T&T reads it and may reply. A reply by email is also general information unless it is part of an Engagement.
C10.4 Users must not submit Confidential Information, sensitive personal data or documents through the assistant.

C11. Guides

C11.1 T&T may publish guides on fraud prevention and safe trade practices. This Section applies from their publication.
C11.2 Guides are general information under Section A2, reflect their date of publication, and may not cover every fraud technique or jurisdiction. Following a guide does not ensure that a transaction is safe.
C11.3 Guides may be shared by link and quoted under Section A5.2. They may not be republished in full, sold or altered without T&T's written consent.

Contact: T&T Consulting Business, LLC, 13575 58th St N, Suite 200, Clearwater, Florida 33760, United States. legal@tudorsgroup.com. +1 813 384 8490.