Terms of service

These Terms are between you and OFACScreen ("we", "us"). These Terms of Service ("Terms") govern your access to and use of the OFACScreen website, platform, API, MCP server, reports, training and every other product or feature we provide (together, the "Service").

By creating an account, buying a report, using the free search or otherwise using the Service, you agree to these Terms. If you use the Service on behalf of a company or other organization, you confirm that you are authorized to bind it, and "you" means that organization. If you do not agree to these Terms, do not use the Service.

The Service is for business and professional use only. By using it you confirm that you are acting for the purposes of your trade, business or profession and not as a consumer.

OFACScreen is a software tool. It compares names, identifiers, addresses, email addresses, websites and phone numbers you submit with records in sanctions, export-control and related lists published by government bodies, and shows possible matches. The lists covered are shown on our Data Sources page. Depending on your plan, the Service also includes batch screening, monitoring, an API and MCP server, match review, audit records and PDF records, jurisdiction flags, staff training with completion records, a partner sheet and other features described on our website.

OFACScreen is an independent service. It is not affiliated with, endorsed by or acting on behalf of the U.S. Department of the Treasury, OFAC or any other government authority.

We may add, change or remove features at any time. If we remove a feature that is a material part of a paid plan, we will tell you in advance. If we discontinue the Service as a whole, we will give subscribers reasonable notice and refund prepaid fees for the period after it ends.

OFACScreen is a tool, not a legal, compliance or advisory service. Nothing in the Service is legal advice, compliance advice or a determination that any person, company, transaction or address is or is not subject to sanctions or export controls. That includes search results, match scores, match levels, jurisdiction flags, reports, PDF records, training modules, quizzes, completion records, the partner sheet, help articles, emails, support replies and any output of the API or MCP server.

You remain solely responsible for:

• your own compliance with the sanctions, export-control, anti-money-laundering and other laws that apply to you;
• deciding whether, and on what terms, to deal with any person, company, vessel, aircraft or address;
• reviewing every possible match, confirming or clearing it, and checking information the Service does not search, such as dates of birth;
• your compliance program, its design, testing and audit, and any filing, report or license application;
• getting advice from qualified legal and compliance professionals where needed.

A result with no match does not mean a party is not sanctioned, and a match does not mean it is. A result or report showing no matches, however it is titled, only records that no entry on the screened lists scored above the matching threshold at the time of the search. It is not a certification, guarantee or official confirmation that a person or company is not sanctioned, not subject to restrictions or safe to do business with, and it is not issued or approved by any government authority. Do not rely on the Service as the sole basis for any decision. Independent testing or audit of your compliance program is done by advisers you choose, not by OFACScreen.

The lists searched by the Service are published by third parties, mainly government bodies. We do not control them, and we do not guarantee that any list, or our copy of it, is complete, accurate or current. A designation can take effect before it appears in a list or in the Service. The Service can be unavailable or delayed, or can return incomplete results, because of errors in our systems or those of our suppliers.

Matching is approximate. The Service can show possible matches that are not the listed party, and can miss a listed party, for example because of spelling, transliteration, abbreviations, the threshold or filters you choose, or information the lists do not contain.

You are responsible for your account, for keeping your credentials and API keys secure, and for everything done through your account, including by team members and anyone you give access to. Tell us at once at [email protected] if you suspect unauthorized access.

You are responsible for the data you submit, including names and other details of people you screen, team members you invite and staff you add to training. You confirm that you have a lawful basis, and have given any notices and obtained any consents required, to submit that data to us and to have us process it as described in our Privacy Policy. You keep all rights in your data and give us the rights we need to process it to provide, secure and improve the Service.

When you screen people from your account, by batch upload, through the API or with monitoring, and when you add staff to training, you are the controller of the personal data you submit ("Customer Data"), and we process it on your behalf as your processor under Article 28 of the EU General Data Protection Regulation (GDPR). This section is our data processing agreement with you. Our Privacy Policy explains the data we process as controller ourselves.

Scope. We process Customer Data to screen it against sanctions lists, return and store results, keep your records, run monitoring and training and send alerts and invitations, for as long as you use the Service and then for the retention periods in our Privacy Policy. Customer Data usually consists of names and other identifying details, such as dates of birth, addresses, countries, email addresses, phone numbers and identification numbers, of the individuals and of the representatives of the companies you screen, typically your customers, suppliers, employees, business partners and counterparties, and of the staff you train.

As your processor, we will:

• process Customer Data only to provide the Service, in line with these Terms and your use of the Service, which together are your documented instructions;
• ensure that people with access to Customer Data are bound by confidentiality;
• take appropriate technical and organizational security measures;
• use sub-processors, such as the hosting and email providers listed in our Privacy Policy, only under written terms that give equivalent protection, and tell you about intended changes so you can object;
• transfer Customer Data outside the EU/EEA only with appropriate safeguards, such as the EU Standard Contractual Clauses;
• help you, as far as reasonably possible, to respond to requests from the people concerned and to meet your security and breach notification obligations;
• notify you without undue delay after becoming aware of a personal data breach affecting Customer Data;
• delete Customer Data when it is no longer needed to provide the Service, as described in our Privacy Policy, or earlier at your request, unless the law requires us to keep it; and
• make available the information reasonably needed to show compliance with this section, and allow for and contribute to audits, including inspections, by you or an auditor you appoint, on reasonable notice and at your cost.

You are responsible for having a lawful basis for the Customer Data you submit and for giving any notices the law requires to the people concerned.

Training modules, quizzes, the partner sheet and similar materials are general information about sanctions and export controls at the date shown on them. They are not tailored to your business and are not a certification of any person or company. Completing them does not mean that you, your staff or your partners meet any legal or regulatory requirement. Laws change, and the materials may not reflect a change at once.

A completion record or verification page shows that the training was completed through a training link or an account. We do not verify who completed it; the name shown is the one entered by the account. Using our materials or sending them to others does not create any relationship between OFACScreen and those people.

Paid plans and their limits are described on our pricing page. A free trial may be offered at our discretion. Payments are processed by Stripe. Prices exclude taxes unless stated, and you pay any taxes that apply.

Subscriptions renew automatically at the end of each billing period (monthly or annual) until cancelled. You can cancel at any time in your account settings. Cancellation takes effect at the end of the current period, and no partial refunds are given. We may change prices with 30 days' notice; a new price applies from your next renewal.

One-off screening reports. A single screening report is a one-time purchase and nothing recurs. If a report does not give you what you needed, reply to your receipt within 7 days of purchase and we will refund it in full to the original payment method.

You must not:

• use the Service for any unlawful purpose, including to evade, or help anyone evade, sanctions or export controls, or to disclose an investigation or report to its subject where the law forbids it;
• submit personal data you have no lawful basis to process;
• use training invitations, team invitations or any other feature to send messages to people who have not agreed to receive them, or for spam or phishing;
• try to gain unauthorized access to the Service, other accounts or our systems, or test their security without our written permission;
• reverse engineer, scrape or copy the Service or its data, except as the law expressly allows;
• resell, sublicense or redistribute the Service, its data or its output without our written agreement;
• exceed your plan's limits by automated or other means, or interfere with the Service's performance.

You confirm that you are not, and are not owned or controlled by, a person on a sanctions list covered by the Service. We may refuse or end service to anyone where providing it would breach sanctions or other law that applies to us.

We may suspend access, limit sending or remove content where we reasonably believe these rules are being broken, or to protect the Service and its users.

The Service keeps records of searches, results, match decisions and training as described in our Privacy Policy. U.S. sanctions regulations (31 CFR 501.601) require persons subject to them to keep certain records for 10 years. Our records can support that, but they do not replace your own: you are responsible for keeping the records the law requires of you, for as long as it requires, including by exporting them.

The Service, including its software, design, matching logic, training materials and the way we compile and present the source lists, belongs to us or our licensors. The sanctions lists themselves remain publications of the authorities that issue them. You may use results, reports and records for your own compliance and business records, and share them with your auditors, advisers, regulators and counterparties.

THE SERVICE AND ALL DATA, RESULTS, REPORTS, RECORDS, TRAINING AND OTHER MATERIALS AND OUTPUT ARE PROVIDED "AS IS" AND "AS AVAILABLE", WITH ALL FAULTS. TO THE MAXIMUM EXTENT PERMITTED BY LAW, OFACSCREEN DISCLAIMS ALL WARRANTIES, CONDITIONS AND REPRESENTATIONS, WHETHER EXPRESS, IMPLIED OR STATUTORY. THIS INCLUDES ANY WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, SATISFACTORY QUALITY, TITLE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, TIMELINESS OR UNINTERRUPTED OR ERROR-FREE OPERATION, AND ANY WARRANTY THAT THE SERVICE WILL IDENTIFY EVERY SANCTIONED OR RESTRICTED PARTY OR WILL MEET YOUR LEGAL OR REGULATORY OBLIGATIONS.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, OFACSCREEN ACCEPTS NO RESPONSIBILITY AND NO LIABILITY FOR YOUR COMPLIANCE OR FOR THE CONSEQUENCES OF YOUR DECISIONS. IN PARTICULAR, OFACSCREEN, ITS AFFILIATES, AND ITS AND THEIR DIRECTORS, OFFICERS, EMPLOYEES, CONTRACTORS AND SUPPLIERS ARE NOT LIABLE FOR ANY LOSS, DAMAGE, COST OR LIABILITY ARISING OUT OF OR IN CONNECTION WITH:

• ANY DECISION TO DEAL OR NOT TO DEAL WITH ANY PERSON, COMPANY, VESSEL, AIRCRAFT OR ADDRESS;
• ANY FINE, PENALTY, ENFORCEMENT ACTION, BLOCKED OR REJECTED TRANSACTION, LICENSE REQUIREMENT OR REGULATORY FINDING AGAINST YOU OR ANYONE ELSE;
• ANY MISSED MATCH, FALSE MATCH, MATCH SCORE OR JURISDICTION FLAG;
• ANY ERROR, OMISSION, DELAY OR CHANGE IN A LIST OR ITS PUBLICATION, OR IN OUR COPY OF IT;
• ANY UNAVAILABILITY, INTERRUPTION, DELAY OR LOSS OF DATA IN THE SERVICE;
• ANY TRAINING, COMPLETION RECORD, PARTNER SHEET, REPORT, HELP ARTICLE, SUPPORT REPLY OR API OR MCP OUTPUT, OR ANY USE OF THEM BY YOU OR BY ANYONE YOU SHARE THEM WITH;
• ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, REVENUE, BUSINESS, CONTRACTS, GOODWILL OR DATA;

IN EACH CASE HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY, WHETHER CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, STATUTE OR OTHERWISE, AND EVEN IF WE WERE TOLD THE LOSS WAS POSSIBLE.

IF, DESPITE THE ABOVE, OFACSCREEN IS FOUND LIABLE, OUR TOTAL LIABILITY FOR ALL CLAIMS TOGETHER ARISING OUT OF OR IN CONNECTION WITH THE SERVICE OR THESE TERMS SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNT YOU PAID US FOR THE SERVICE IN THE TWELVE (12) MONTHS BEFORE THE EVENT GIVING RISE TO THE FIRST CLAIM AND (B) ONE HUNDRED U.S. DOLLARS (US$100).

Nothing in these Terms excludes or limits liability that cannot be excluded or limited by law, including liability for loss caused intentionally or through gross negligence, for fraud, or for death or personal injury caused by negligence. In those cases our liability is limited to the extent the law allows. These limits are a fundamental part of the price of the Service and apply even if a remedy fails of its essential purpose.

You must notify us of any claim in writing within twelve (12) months after you became, or should have become, aware of the circumstances giving rise to it. Otherwise the claim is waived.

You will defend, indemnify and hold harmless OFACScreen, its affiliates, and its and their directors, officers, employees and contractors from and against any claim, loss, damage, fine, penalty, cost and expense (including reasonable legal fees) arising out of or relating to: your use of the Service or its output; your compliance decisions and your dealings with any third party; the data you submit, including data about people you screen, invite or train; your breach of these Terms; or your breach of any law.

You can stop using the Service and cancel your subscription at any time. We may suspend or end your access if you breach these Terms, if you do not pay, if the law requires it, or to protect the Service or other users. When access ends, your right to use the Service ends. We keep records as described in our Privacy Policy. Sections 3, 4, 6, 7, 10, 11, 12, 13, 14, 17 and 18 continue to apply after termination.

We may update these Terms. For a material change, we will tell account holders by email or in the Service at least 30 days before it takes effect, unless the change is required by law or concerns a new feature, in which case it can take effect sooner. If you do not agree, stop using the Service and cancel before the change takes effect. Continuing to use the Service after that means you accept the updated Terms.

These Terms, and any dispute arising out of or in connection with them or the Service, are governed by Swedish law, without regard to its conflict-of-laws rules. Disputes will be settled by the Swedish courts, with the Stockholm District Court (Stockholms tingsrätt) as the court of first instance. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

These Terms, together with our Privacy Policy and any order or plan terms you accept, are the entire agreement between you and us about the Service. If any part of these Terms is found unenforceable, it will be enforced to the maximum extent permitted and the rest remains in effect. Our failure to enforce a right is not a waiver. You may not transfer these Terms without our consent; we may transfer them, and our rights and obligations under them, to an affiliate or to a successor to the Service, and we will tell you if this happens. We are not liable for failures caused by events beyond our reasonable control, including outages at hosting or payment providers and failures by authorities to publish or update their lists. Nothing in these Terms creates a partnership, agency or fiduciary relationship.

Email: [email protected].