Arthr upholds the highest standards of business ethics and conduct, ensuring compliance with economic and export sanctions laws applicable to our operations. These laws, enacted by entities such as the United Nations, United Kingdom, United States, European Union, and others, are designed to combat various illicit activities, including terrorism, narcotics trafficking, human rights abuses, and the proliferation of weapons of mass destruction.
Oversight of our compliance efforts is provided by Arthr’s Chief Executive and Chief Commercial Officer, ensuring that our policies and procedures align with regulatory requirements.
This commitment extends to all interactions involving users, partners, employees, consultants, or any other parties associated with Arthr.
Key Principles:
Arthr adopts a risk-based approach to identify individuals and technologies potentially subject to economic or export sanctions. These sanctions encompass:
Economic or financial sanctions, which include targeted asset freezes, restrictions on financial markets, and bans on conducting business with specific individuals, groups, or countries.
Trade sanctions or export controls, which entail limitations on the export of goods or technology to certain countries, individuals, or groups.
Sanctioned entities or goods are often listed, and individuals, entities, or governments subject to sanctions can be found on specific lists maintained by regulatory bodies such as the Office of Foreign Assets Control in the U.S. and HM Treasury in the UK.
Compliance with Economic Sanctions:
Arthr employs a risk-based approach to comply with economic sanctions, screening users applying to join the Arthr community and periodically reviewing user accounts. Employees are trained to remain vigilant for any indications of users or partners being subject to economic sanctions, with any concerns promptly reported to the Chief Commercial Officer or Chief Executive Officer.
Compliance with Trade Sanctions and Export Controls:
Arthr applies a risk-based approach to comply with export controls and trade sanctions by screening technology descriptions before posting them on the Arthr platform. Employees are trained to recognize any indications of users attempting to buy or sell technology subject to export controls, with any concerns reported immediately to the Chief Commercial Officer or Chief Executive Officer.
Whistleblower Protection:
Arthr is committed to protecting whistleblowers and ensuring the highest standards of openness, probity, and accountability in compliance matters.
External Sanctions Process:
Arthr implements robust processes and procedures to comply with sanctions policies. We utilize Dow Jones’ Risk Center for expert and up-to-date information to conduct thorough assessments and investigations. Our high-level processes include:
Screening new prospective customers against sanctions lists.
Quarterly checks of the entire customer and prospective customer list against sanctions data.
All outcomes of these tests are stored in our SalesForce system to ensure auditability and robust tracking. In the event of a sanctions flag, interaction with the customer is immediately suspended, and the matter is escalated to the Chief Commercial Officer and Chief Executive Officer for further assessment, including legal advice if necessary. If an organization or associated individuals or states are confirmed to be under sanctions, all engagement is ceased immediately.