ORO TECHNOLOGIES LLC
GLOBAL SANCTIONS, EXPORT CONTROL AND RESTRICTED JURISDICTIONS POLICY
Global Trade Compliance, Economic Sanctions, Export Controls, Restricted Territories, Prohibited Persons, International Regulatory Compliance and Platform Access Framework
1. PURPOSE, LEGAL STATUS AND GLOBAL COMPLIANCE FRAMEWORK
This Global Sanctions, Export Control and Restricted Jurisdictions Policy ("Policy") establishes the global compliance framework governing economic sanctions, export-control regulations, restricted jurisdictions, prohibited users, governmental restrictions, trade-compliance obligations, international regulatory requirements, and access limitations applicable to the ORO Marketplace Platform operated by ORO TECHNOLOGIES LLC ("ORO," the "Company," or the "Platform").
This Policy applies globally to all Users, Drivers, Providers, Merchants, Business Partners, Contractors, Technology Vendors, Affiliates, Commercial Counterparties, Platform Participants, Third-Party Service Providers, Visitors, and any individual or entity accessing, using, interacting with, registering on, or attempting to access the Platform.
This Policy forms an integral part of ORO's unified legal, compliance, cybersecurity, governance, risk-management, privacy, accessibility, safety, technology, and international regulatory architecture and shall be interpreted together with:
Terms and Conditions;
Global Platform Legal Framework;
Privacy Policy;
Payments and Financial Compliance Framework;
Law Enforcement and Legal Compliance Framework;
Acceptable Use Policy;
Driver and Provider Framework;
Community Standards;
Accessibility Policies;
and all related policies, disclosures, notices, compliance frameworks, and future amendments published by ORO.
2. COMMITMENT TO INTERNATIONAL SANCTIONS COMPLIANCE
ORO is committed to complying with applicable international sanctions, trade restrictions, export-control laws, anti-terrorism regulations, anti-money laundering requirements, financial-crime prevention measures, and governmental restrictions applicable to its operations.
Accordingly, ORO may implement compliance controls designed to prevent access to the Platform by individuals, organizations, entities, jurisdictions, or activities subject to applicable legal restrictions.
Nothing contained within the Platform shall be interpreted as authorizing any activity prohibited under applicable sanctions, export-control laws, anti-terrorism laws, trade restrictions, embargo regulations, or governmental directives.
3. SANCTIONS AUTHORITIES AND REGULATORY SOURCES
Compliance measures may be based upon laws, regulations, directives, restrictions, sanctions programs, governmental notices, enforcement actions, regulatory guidance, or other legal requirements issued by:
The United States Department of the Treasury;
The Office of Foreign Assets Control (OFAC);
The United States Department of Commerce;
The Bureau of Industry and Security (BIS);
The United States Department of State;
The United Nations Security Council;
The European Union;
The United Kingdom Office of Financial Sanctions Implementation (OFSI);
Canada;
Australia;
or any other competent governmental authority.
ORO reserves the right to rely upon any sanctions source, compliance database, governmental notice, risk-assessment methodology, or compliance provider deemed appropriate by the Company.
4. PROHIBITED PERSONS AND RESTRICTED PARTIES
Access to the Platform may be denied, restricted, suspended, limited, terminated, investigated, monitored, or blocked where ORO reasonably determines that a person or entity may be:
subject to sanctions;
listed on a governmental sanctions list;
associated with sanctioned persons;
owned or controlled by sanctioned persons;
acting on behalf of sanctioned persons;
associated with terrorist organizations;
associated with criminal enterprises;
subject to export restrictions;
subject to governmental prohibitions;
subject to law-enforcement restrictions;
or otherwise prohibited under applicable law.
The Company may take such actions without prior notice where permitted by applicable law.
5. RESTRICTED JURISDICTIONS
Access to the Platform may be restricted, limited, suspended, blocked, terminated, unavailable, or otherwise prohibited in certain countries, territories, regions, jurisdictions, geographic locations, or governmental areas subject to legal restrictions.
The availability of the Platform in a specific jurisdiction shall not be interpreted as a representation that all services are legally available in that location.
Users remain solely responsible for ensuring that their access to the Platform complies with applicable local laws.
ORO reserves the unrestricted right to modify geographic availability at any time.
6. EXPORT CONTROL COMPLIANCE
The Platform, software, applications, source code, object code, voice technologies, artificial intelligence systems, accessibility technologies, data-processing systems, technical information, documentation, software updates, APIs, security systems, and related technologies may be subject to export-control laws and regulations.
Users agree not to:
export;
re-export;
transfer;
disclose;
share;
download;
provide access to;
or otherwise make available
any restricted technology in violation of applicable export-control laws.
Users remain solely responsible for complying with all export-control obligations applicable to their activities.
7. USER REPRESENTATIONS AND WARRANTIES
By accessing or using the Platform, the User represents and warrants that:
the User is not subject to sanctions;
the User is not acting on behalf of a sanctioned person;
the User is not located within a prohibited jurisdiction where access is restricted by applicable law;
the User is not included on any list prohibiting access under applicable law;
the User is not using the Platform for prohibited activities;
the User is not facilitating transactions prohibited under applicable sanctions laws;
and the User will immediately cease use of the Platform if such representations become inaccurate.
These representations are deemed continuously renewed throughout the User's relationship with the Platform.
8. COMPLIANCE SCREENING AND VERIFICATION
ORO reserves the right, but assumes no obligation, to conduct compliance reviews, sanctions screening, risk assessments, identity verification, fraud-prevention reviews, jurisdictional reviews, account investigations, transaction monitoring, provider reviews, or other compliance procedures.
Such reviews may occur:
before registration;
during registration;
after registration;
during transactions;
after transactions;
during investigations;
or at any other time.
The Company may rely upon automated systems, third-party compliance providers, governmental databases, commercial screening tools, artificial intelligence technologies, risk-scoring systems, or manual reviews.
8-A. NO DUTY TO VERIFY OR MONITOR ALL USERS
ORO's compliance controls are risk-management tools intended to support lawful Platform operations and do not constitute a guarantee that all sanctioned persons, restricted entities, prohibited organizations, criminal actors, governmental targets, politically exposed persons, export-controlled parties, or other restricted individuals will be identified, detected, screened, monitored, prevented, blocked, suspended, or removed.
The User expressly acknowledges that no compliance system can guarantee complete detection of all prohibited activities, identities, affiliations, ownership structures, sanctions exposure, beneficial ownership arrangements, jurisdictional risks, or regulatory violations.
Accordingly, ORO does not assume any duty to continuously monitor all Users, Providers, Merchants, Business Partners, Contractors, or third parties, and shall not be liable for the acts, omissions, conduct, affiliations, transactions, or legal status of independent third parties operating outside the Company's reasonable control.
9. RIGHT TO SUSPEND, RESTRICT OR TERMINATE ACCESS
ORO reserves the unrestricted right to:
deny access;
suspend access;
terminate accounts;
freeze functionality;
limit services;
cancel transactions;
restrict payments;
block communications;
disable features;
or otherwise take protective measures
where ORO determines, in its sole discretion, that continued access may create legal, regulatory, financial, operational, compliance, reputational, cybersecurity, safety, or sanctions-related risk.
Such actions may be taken without prior notice where permitted by applicable law.
10. NO OBLIGATION TO PROVIDE SERVICES
Nothing contained within the Platform shall create any obligation requiring ORO to provide services, maintain accounts, process requests, facilitate transactions, continue business relationships, support access, or maintain functionality where doing so may create legal or compliance risk.
The Company reserves absolute discretion to discontinue access where necessary to comply with applicable law or protect legitimate business interests.
11. THIRD-PARTY PROVIDERS AND COMPLIANCE LIMITATIONS
The Platform relies upon independent third-party service providers including:
payment processors;
cloud providers;
communications providers;
security vendors;
identity-verification vendors;
technology partners;
mapping providers;
artificial intelligence providers;
accessibility technology providers;
and other external service providers.
Such third parties may independently impose sanctions-related restrictions, account limitations, geographic restrictions, compliance reviews, service suspensions, or access limitations.
ORO shall not be liable for actions taken independently by such third parties.
12. NO CIRCUMVENTION OF SANCTIONS
Users may not use:
VPNs;
proxy services;
identity-masking tools;
false registration information;
third-party credentials;
false locations;
artificial account structures;
or any technological mechanism
for the purpose of circumventing sanctions restrictions, geographic restrictions, compliance controls, export restrictions, governmental prohibitions, or Platform limitations.
Any attempt to circumvent compliance controls may result in immediate account termination.
13. COOPERATION WITH GOVERNMENTAL AUTHORITIES
ORO reserves the right to cooperate with:
law-enforcement agencies;
regulatory authorities;
governmental bodies;
courts;
administrative agencies;
financial institutions;
sanctions authorities;
and other legally authorized entities
to the extent required or permitted by applicable law.
Such cooperation may include disclosure, preservation, restriction, suspension, reporting, investigation support, or other legally authorized actions.
14. LIMITATION OF LIABILITY
To the maximum extent permitted by applicable law, ORO TECHNOLOGIES LLC, its affiliates, subsidiaries, officers, directors, employees, contractors, licensors, technology providers, service providers, infrastructure providers, vendors, and representatives shall not be liable for any damages, losses, liabilities, claims, penalties, business interruptions, lost profits, lost opportunities, regulatory consequences, account restrictions, transaction limitations, service denials, or operational impacts arising from:
sanctions compliance activities;
export-control compliance measures;
restricted-jurisdiction controls;
governmental restrictions;
third-party compliance actions;
account reviews;
service limitations;
risk-management decisions;
or legally required compliance actions.
15. CORPORATE DISCRETION AND POLICY MODIFICATIONS
ORO reserves the unrestricted right to modify, supplement, update, interpret, suspend, expand, replace, or discontinue this Policy at any time.
Compliance requirements may change rapidly due to legal, regulatory, geopolitical, cybersecurity, financial-crime, trade, or governmental developments.
Continued use of the Platform constitutes acceptance of all modifications.
16. GLOBAL LEGAL INTEGRATION NOTICE
This Global Sanctions, Export Control and Restricted Jurisdictions Policy forms part of the unified legal, regulatory, compliance, cybersecurity, governance, accessibility, safety, privacy, technology, financial-compliance, and risk-management architecture governing the ORO Marketplace Platform operated by ORO TECHNOLOGIES LLC.
This Policy shall be interpreted together with all related legal frameworks, disclosures, compliance standards, operational requirements, and future amendments published by ORO.
Continued access to, registration on, interaction with, or use of the Platform constitutes legally binding acknowledgment and acceptance of this Policy and all related compliance frameworks to the maximum extent permitted by applicable law.