Draft — pending legal review. This text is a draft prepared for legal review. It is not final, it may change before ARCA Sanctions is offered commercially, and the passages marked as pending have yet to be completed by ARCA Compliance.

Draft — pending legal reviewLast updated: 22 October 2026

Terms of service

These terms govern the use of ARCA Sanctions (the «Service»), a product of ARCA Compliance (the «Provider»). By creating an organization or using the Service you accept them on behalf of the organization you represent (the «Customer»).

1. The Service

ARCA Sanctions is a screening tool. It compares the names and data of the people, companies, vessels and aircraft the Customer submits — one at a time, in batches, through the API or from its register of subjects — against sanctions lists published by governments and international bodies, the Customer's own lists and, where that screening is enabled for the Customer, lists of politically exposed persons (PEP), and it helps the Customer review, decide and document the potential matches (hits).

A hit is a possible match, not a determination. The Customer remains solely responsible for its compliance program, for deciding whether a subject is the listed person or entity, for its screening policy (lists, thresholds, who approves) and for any action the law requires of it, such as blocking, rejecting or reporting. The Provider does not give legal advice and does not report to any authority on the Customer's behalf.

2. List data

Sanctions lists are public data published by governments and international bodies such as OFAC, the United Nations, the European Union and the United Kingdom. The Service downloads them from each publisher, normally every day, and records for each release its source address, the publisher's hash, the date and the record count. The Provider is not affiliated with, endorsed or approved by any of those bodies.

The Provider does not warrant that a list is complete or free of errors, nor that a change by a publisher is available in the Service at the moment it is published: a release becomes available once it has been downloaded and has passed the Service's integrity checks. The freshness of every list is shown in the Service.

PEP data come from a third-party source whose licence for commercial use is [PENDING: PEP data licence]. Until it is settled, PEP screening may be unavailable or limited.

3. Accounts

Accounts are created and managed on the ARCA Compliance platform, which authenticates every person who signs in to the Service. The Customer is responsible for the people it invites, for the roles it gives them, for keeping credentials and API keys confidential and for every action taken through its accounts. The Customer must give accurate organization and contact details and keep them current.

4. Acceptable use

The Customer may use the Service only to screen its own customers, counterparties, employees and suppliers, or those of organizations that have authorized it to do so, for compliance purposes (anti-money laundering, counter-terrorist financing, sanctions and export controls) and in compliance with applicable law, including data protection law.

The Customer must not use the Service as a consumer report or as the sole basis for decisions about a person's credit, employment, insurance or housing; submit data it has no right to process; interfere with the Service or its limits; attempt to access other customers' data; extract the reference lists in bulk; or resell the Service.

5. Certificates and evidence

Each screening can produce a certificate that records the subject as submitted, the lists and releases consulted, the policy, the verdict and the hits with their decisions at the moment it is issued, sealed with a signature and a digest that anyone can check at the Service's public verification address.

A certificate attests what the Service did and returned at that moment. It does not certify that a subject is not sanctioned, nor the result of any later screening.

6. API

Access to the API uses credentials issued through the ARCA Compliance platform, limited by scopes. The API applies rate limits; current values are documented in the API reference. The Idempotency-Key lets a retry return the original result instead of screening twice. The Provider may change the API with reasonable notice; breaking changes are announced in advance.

7. Subscription and trial

Plans and prices are [PENDING: plans and prices]. Subscriptions, invoicing and payments are handled by the ARCA Compliance platform under its own terms. A subscription that lapses may limit or suspend the Service until it is renewed; the Customer's data are kept as described in the Privacy policy.

8. Availability and no warranty

The Service is provided «as is» and «as available». The Provider makes reasonable efforts to keep it running and its lists current, but does not warrant uninterrupted availability, nor that every listed person or entity will be found, nor that every hit is a true match. Matching depends on the data submitted, on transliterations and on the thresholds the Customer chooses; it reduces risk, it does not replace the Customer's review.

9. Limitation of liability

To the extent permitted by law, the Provider is not liable for indirect, incidental or consequential damages, lost profits, regulatory penalties or the consequences of a missed or mistaken match arising from the use of or inability to use the Service. The Provider's total liability for any claim is limited to the fees the Customer paid for the Service in the twelve months before the event giving rise to the claim.

10. Termination

The Customer may stop using the Service at any time by closing its organization on the ARCA Compliance platform. The Provider may suspend or terminate access for breach of these terms, non-payment or legal requirement, with notice where practicable. After termination the Customer may request an export of its data during the 30 days following cancellation; the Provider delivers it on request. Data are then deleted in line with the Privacy policy and the minimum retention described there.

11. Changes

The Provider may update these terms. Material changes are announced in the Service or by email at least 15 days before they take effect. Continued use after that date is acceptance of the new terms.

12. Governing law and contact

These terms are governed by the laws of [PENDING: jurisdiction], and any dispute is subject to the courts of [PENDING: jurisdiction], without prejudice to mandatory provisions that apply to the Customer. Questions about these terms go to [PENDING: contact email].