1. Introduction and Commitment

ARK PLATFORMS, EUROPE LIMITED, operating as Bizly ("Bizly," "we," "us," or "our"), is committed to full compliance with all applicable international sanctions, export controls, and trade restrictions. This Sanctions Policy outlines our approach to sanctions compliance and our procedures for screening customers, transactions, and business relationships to ensure we do not facilitate or engage in any prohibited activities. Sanctions are legal restrictions imposed by governments and international organizations to achieve foreign policy and national security objectives, and violations can result in severe criminal and civil penalties. We take our sanctions obligations seriously and have implemented robust controls and procedures to prevent sanctions violations.

2. Applicable Sanctions Regimes

We comply with sanctions programs administered by the following authorities: (a) United Nations (UN) Security Council Sanctions: We comply with all UN sanctions resolutions, which are binding on all UN member states; (b) European Union (EU) Sanctions: As a UK-based company, we comply with EU sanctions that continue to apply in the UK and with EU sanctions more broadly; (c) United Kingdom (UK) Sanctions: We comply with sanctions administered by the UK Office of Financial Sanctions Implementation (OFSI) under the Sanctions and Anti-Money Laundering Act 2018; (d) United States (US) Sanctions: We comply with sanctions administered by the US Office of Foreign Assets Control (OFAC), particularly when dealing with US persons, US dollar transactions, or US-connected activities; (e) Other Relevant Sanctions: We may also comply with sanctions imposed by other jurisdictions where we operate or where our customers are located. In cases where sanctions regimes conflict, we will apply the most restrictive requirements to ensure full compliance.

3. Types of Sanctions

Sanctions can take various forms, and we comply with all applicable types, including: (a) Comprehensive Sanctions: Broad prohibitions on virtually all transactions and dealings with certain countries or territories (e.g., North Korea, Iran, Syria, Cuba); (b) Sectoral Sanctions: Restrictions on specific sectors of a country's economy (e.g., energy, financial services, defense); (c) List-Based Sanctions: Prohibitions on transactions with specifically designated individuals, entities, or vessels listed on sanctions lists; (d) Asset Freezes: Requirements to freeze assets and funds of designated persons and prohibitions on making assets or funds available to them; (e) Trade Restrictions: Prohibitions or restrictions on the import, export, or trade of certain goods, services, or technology; (f) Financial Sanctions: Restrictions on financial transactions, payments, or investments involving sanctioned parties; (g) Travel Bans: Restrictions on travel or entry of designated individuals (less relevant to our business but considered in our screening). We monitor all these types of sanctions and update our compliance procedures as sanctions regimes evolve.

4. Prohibited Activities

In accordance with applicable sanctions, we prohibit the following activities: (a) Providing services to individuals, entities, or governments that are subject to sanctions; (b) Forming companies or facilitating business activities that would benefit sanctioned parties; (c) Processing transactions involving sanctioned countries, territories, or parties; (d) Engaging in business with entities that are owned or controlled (directly or indirectly) by sanctioned parties; (e) Facilitating trade in goods or services that are subject to sanctions or export controls; (f) Providing services that would enable or facilitate sanctions evasion by others; (g) Dealing with vessels, aircraft, or other assets that are subject to sanctions; (h) Engaging in activities that would violate sectoral sanctions or other targeted restrictions; (i) Providing services to parties located in or operating from comprehensively sanctioned countries. We will refuse service to any party that we determine is subject to sanctions or that poses a sanctions risk.

5. Sanctions Screening Procedures

We have implemented comprehensive sanctions screening procedures to identify and prevent transactions with sanctioned parties. Our screening procedures include: (a) Customer Screening: We screen all customers at onboarding and on an ongoing basis against relevant sanctions lists; (b) Transaction Screening: We screen all transactions, payments, and orders for sanctions risks; (c) Beneficial Owner Screening: We screen beneficial owners and controlling parties of companies formed through our services; (d) Counterparty Screening: We screen third-party service providers, partners, and other counterparties; (e) Geographic Screening: We assess the sanctions risk associated with countries, territories, and jurisdictions involved in transactions; (f) Automated Screening: We use automated screening tools and software to check names, addresses, and other identifying information against sanctions lists; (g) Manual Review: We conduct manual reviews of screening results, potential matches, and high-risk transactions; (h) Ongoing Monitoring: We continuously monitor our customer base and transactions for changes in sanctions status or risk. Screening is conducted against consolidated sanctions lists from all relevant authorities, including OFSI, OFAC, UN, EU, and other applicable sources.

6. Sanctions Lists

We screen against the following sanctions lists, among others: (a) UK OFSI Consolidated List: The UK's consolidated list of financial sanctions targets; (b) US OFAC Specially Designated Nationals (SDN) List: OFAC's list of individuals and entities subject to US sanctions; (c) US OFAC Consolidated Sanctions List: OFAC's comprehensive list of all sanctions programs; (d) EU Consolidated Sanctions List: The EU's consolidated list of persons, groups, and entities subject to EU financial sanctions; (e) UN Consolidated Sanctions List: The UN's consolidated list of individuals and entities subject to Security Council sanctions; (f) Sectoral Sanctions Identifications (SSI) List: OFAC's list of entities subject to sectoral sanctions; (g) Non-SDN Lists: Various other OFAC lists, including the Foreign Sanctions Evaders List, Palestinian Legislative Council List, and others; (h) Country-Specific Lists: Lists associated with specific sanctions programs (e.g., Iran, North Korea, Russia); (i) Other Relevant Lists: Lists from other jurisdictions or international organizations as applicable. We update our screening databases regularly to ensure we are screening against the most current versions of all sanctions lists.

7. Screening Matches and Investigations

When our screening procedures identify a potential match with a sanctions list, we follow this process: (a) Initial Review: We conduct an initial review to determine whether the potential match is a true match or a false positive; (b) Enhanced Due Diligence: If the match cannot be immediately ruled out, we conduct enhanced due diligence, including requesting additional information from the customer; (c) Name Matching Analysis: We analyze the quality of the match, considering factors such as name similarity, date of birth, address, nationality, and other identifying information; (d) Risk Assessment: We assess the overall sanctions risk, considering the customer's profile, transaction patterns, and other relevant factors; (e) Escalation: Potential true matches or high-risk cases are escalated to senior management and our compliance officer; (f) Decision: We make a final determination on whether to proceed with the relationship or transaction, refuse service, or seek additional guidance; (g) Documentation: We document all screening results, investigations, and decisions for audit and regulatory purposes; (h) Reporting: If we identify a true match or a sanctions violation, we report it to the relevant authorities as required by law. We err on the side of caution and will refuse service if we cannot conclusively rule out a sanctions risk.

8. Ownership and Control Screening

Sanctions can apply not only to designated parties themselves but also to entities that are owned or controlled by designated parties. We therefore screen for ownership and control relationships, including: (a) Screening beneficial owners and ultimate beneficial owners (UBOs) of companies formed through our services; (b) Screening directors, officers, and other controlling persons; (c) Identifying and screening parent companies, subsidiaries, and affiliated entities; (d) Assessing whether an entity is owned or controlled (directly or indirectly) by a sanctioned party; (e) Applying the "50% rule" and other ownership thresholds used by sanctions authorities; (f) Considering both legal ownership and effective control; (g) Requesting and verifying ownership structures and corporate charts; (h) Conducting ongoing monitoring of ownership changes. We will refuse service to entities that are owned or controlled by sanctioned parties, even if the entity itself is not explicitly listed on a sanctions list.

9. Geographic Sanctions Risk

We assess the sanctions risk associated with countries and territories, and we apply enhanced due diligence or refuse service based on geographic risk. Our approach includes: (a) Comprehensively Sanctioned Countries: We generally do not provide services to customers located in or operating from countries subject to comprehensive sanctions (e.g., North Korea, Iran, Syria, Cuba, Crimea region); (b) High-Risk Jurisdictions: We apply enhanced due diligence to customers with connections to high-risk jurisdictions, including countries subject to sectoral sanctions or heightened sanctions risk (e.g., Russia, Belarus, Venezuela); (c) Conflict Zones: We carefully assess customers with connections to conflict zones or areas of geopolitical instability; (d) Sanctions Evasion Hubs: We are vigilant for customers with connections to jurisdictions known for sanctions evasion or lack of sanctions enforcement; (e) Multi-Jurisdictional Connections: We assess the overall sanctions risk when customers have connections to multiple jurisdictions, particularly if some are high-risk; (f) Changing Risk Profiles: We monitor geopolitical developments and update our geographic risk assessments as sanctions regimes evolve. Geographic risk is one factor among many in our overall sanctions risk assessment.

10. Sectoral Sanctions Compliance

Sectoral sanctions impose restrictions on specific sectors of certain countries' economies, particularly Russia. We comply with sectoral sanctions by: (a) Screening customers and transactions against sectoral sanctions lists (e.g., OFAC's SSI List); (b) Identifying customers that operate in sanctioned sectors (e.g., energy, financial services, defense); (c) Understanding the specific prohibitions applicable to each sectoral sanctions program; (d) Refusing or restricting services that would violate sectoral sanctions; (e) Applying enhanced due diligence to customers with connections to sanctioned sectors; (f) Monitoring for changes in sectoral sanctions designations and restrictions; (g) Training our staff on sectoral sanctions requirements and red flags. Sectoral sanctions can be complex and nuanced, and we seek legal advice when necessary to ensure compliance.

11. Export Controls and Trade Restrictions

In addition to financial sanctions, we comply with export controls and trade restrictions that may apply to our services or to goods and services provided by our customers. This includes: (a) Screening for parties on export control lists (e.g., US Entity List, UK Strategic Export Controls); (b) Assessing whether our services could facilitate the export of controlled goods, technology, or services; (c) Refusing service to customers engaged in activities that would violate export controls; (d) Complying with restrictions on trade in certain goods (e.g., military equipment, dual-use items); (e) Understanding end-use and end-user restrictions; (f) Monitoring for red flags indicating potential export control violations; (g) Cooperating with export control authorities as required. While our services primarily involve company formation and legal documentation, we recognize that our customers may use the companies we help form to engage in international trade, and we take steps to ensure we do not facilitate export control violations.

12. Sanctions Evasion Red Flags

We train our staff to identify and report red flags that may indicate sanctions evasion or sanctions risk, including: (a) Customers who are evasive or uncooperative when asked about their business activities, ownership, or connections; (b) Unusual or complex ownership structures that obscure beneficial ownership; (c) Use of shell companies, nominees, or intermediaries without clear business rationale; (d) Customers with connections to high-risk jurisdictions but who claim to operate elsewhere; (e) Transactions or business activities that do not make economic sense or lack clear business purpose; (f) Requests to form companies in jurisdictions that do not align with the customer's stated business activities; (g) Customers who change their information or business activities shortly after onboarding; (h) Involvement of parties with names similar to sanctioned parties; (i) Use of multiple entities or accounts to structure transactions in unusual ways; (j) Reluctance to provide information about source of funds or business relationships; (k) Customers who operate in sanctioned sectors or have business relationships with sanctioned countries. When we identify red flags, we conduct enhanced due diligence and may refuse service if we cannot satisfactorily resolve our concerns.

13. Customer Due Diligence and Information Requests

To comply with sanctions requirements, we may request additional information from customers, including: (a) Detailed information about business activities, products, and services; (b) Information about customers, suppliers, and business partners; (c) Details of ownership structure, including beneficial owners and controlling parties; (d) Information about connections to specific countries, territories, or jurisdictions; (e) Source of funds and source of wealth information; (f) Corporate documents, such as articles of incorporation, shareholder agreements, and organizational charts; (g) Identification documents for beneficial owners and controlling persons; (h) Explanations of unusual or complex transactions or structures; (i) Certifications or attestations regarding sanctions compliance. Customers must provide this information promptly and accurately. Failure to provide requested information or providing false or misleading information may result in refusal of service, account suspension, or termination.

14. Ongoing Monitoring and Periodic Rescreening

Sanctions compliance is not a one-time activity. We conduct ongoing monitoring and periodic rescreening of our customers and transactions, including: (a) Rescreening our entire customer base against updated sanctions lists on a regular basis (at least quarterly); (b) Monitoring for changes in customer information, ownership, or business activities; (c) Monitoring for changes in sanctions regimes, new designations, and updated guidance; (d) Conducting periodic reviews of customer risk profiles and updating risk assessments; (e) Monitoring transactions for unusual patterns or red flags; (f) Responding promptly to new sanctions designations and conducting emergency rescreening when necessary; (g) Reviewing and updating our sanctions compliance procedures and controls; (h) Conducting internal audits and testing of our sanctions compliance program. Ongoing monitoring allows us to identify and respond to sanctions risks that may arise after the initial onboarding.

15. Blocking and Rejecting Transactions

If we identify a transaction or relationship that violates sanctions or poses a sanctions risk, we will take appropriate action, which may include: (a) Blocking Transactions: Immediately blocking or freezing transactions involving sanctioned parties or sanctioned countries; (b) Rejecting Transactions: Refusing to process transactions that would violate sanctions; (c) Suspending Accounts: Suspending accounts of customers who are subject to sanctions or who pose sanctions risks; (d) Terminating Relationships: Terminating business relationships with sanctioned parties or high-risk customers; (e) Freezing Assets: Freezing assets or funds in accordance with asset freeze requirements; (f) Reporting to Authorities: Reporting blocked or rejected transactions to the relevant sanctions authorities as required by law; (g) Maintaining Records: Maintaining detailed records of all blocked or rejected transactions and the reasons for the action; (h) Not Tipping Off: Ensuring we do not tip off the customer or other parties about sanctions concerns or reports to authorities. We will not process transactions or provide services that would violate sanctions, even if requested or demanded by a customer.

16. Reporting to Authorities

We are required to report certain sanctions-related matters to the relevant authorities, and we comply with all reporting obligations, including: (a) Reporting blocked or rejected transactions to OFSI, OFAC, or other relevant authorities within required timeframes; (b) Reporting asset freezes and frozen funds; (c) Reporting suspected sanctions violations or evasion attempts; (d) Providing information to authorities in response to requests or investigations; (e) Cooperating with sanctions enforcement actions and investigations; (f) Maintaining confidentiality of reports and not disclosing to the subject of the report; (g) Documenting all reports and maintaining records for audit purposes. We take our reporting obligations seriously and have procedures in place to ensure timely and accurate reporting.

17. Training and Awareness

We provide regular training to all employees on sanctions compliance, including: (a) Overview of applicable sanctions regimes and requirements; (b) How to use sanctions screening tools and interpret screening results; (c) How to identify and escalate sanctions red flags; (d) Procedures for handling potential sanctions matches and high-risk customers; (e) Reporting obligations and procedures; (f) Consequences of sanctions violations for the company and individuals; (g) Updates on changes in sanctions regimes and new designations; (h) Case studies and examples of sanctions violations and evasion schemes. Training is provided to all new employees as part of onboarding and is refreshed regularly for all staff. We maintain records of all training provided and ensure employees understand their responsibilities.

18. Governance and Oversight

Our sanctions compliance program is overseen by senior management and our compliance officer, who are responsible for: (a) Developing, implementing, and maintaining our sanctions compliance policies and procedures; (b) Ensuring adequate resources and technology are allocated to sanctions compliance; (c) Monitoring the effectiveness of our sanctions compliance program; (d) Conducting periodic risk assessments and updating controls as needed; (e) Overseeing sanctions screening, investigations, and decision-making; (f) Ensuring timely reporting to authorities; (g) Liaising with sanctions authorities and responding to inquiries; (h) Reporting to the board of directors on sanctions compliance matters; (i) Ensuring compliance with all applicable sanctions laws and regulations. We are committed to maintaining a robust and effective sanctions compliance program.

19. Record Keeping

We maintain comprehensive records of our sanctions compliance activities, including: (a) Records of all sanctions screening activities and results; (b) Documentation of investigations into potential sanctions matches; (c) Records of decisions to accept, refuse, or terminate customers or transactions; (d) Reports to sanctions authorities; (e) Training records; (f) Risk assessments and audits; (g) Policies, procedures, and updates; (h) Communications with authorities and legal advisors. Records are retained for at least 6 years or as required by applicable laws and regulations. Records are stored securely and are available for review by authorities upon request.

20. Updates to This Policy

We reserve the right to update this Sanctions Policy at any time to reflect changes in sanctions regimes, legal requirements, or our compliance procedures. Updates will be posted on our website with a new "Last updated" date. We encourage you to review this policy periodically to stay informed about our sanctions compliance approach.

21. Contact Us

If you have any questions about this Sanctions Policy, please contact us at:

ARK PLATFORMS, EUROPE LIMITED
Attention: Sanctions Compliance Officer
OFFICE 12, INITIAL BUSINESS CENTRE
WILSON BUSINESS PARK
MANCHESTER, M40 8WN
United Kingdom

Email: info@arkplatforms.co.uk
Phone: +44 7308 506068