Compliance posture

§ 1What we are not

We are not lawyers and this is not legal advice. The sanctions position affecting Syria has changed repeatedly and can change again at short notice, including in ways that are not visible from a published list. Every customer takes its own advice on its own facts, in its own jurisdictions. Nothing on this site is a determination that a transaction is permitted.

§ 2Screening

• Every customer and every data partner is screened before onboarding against the public consolidated sanctions lists, at minimum the United States Specially Designated Nationals list and the European Union consolidated list.
• Every screening is logged with the list version used, so a decision can be reconstructed as it stood on the day it was made.
• A potential match is never auto-cleared. It escalates to a person, always, including when the match looks weak.
• Screening applies to the parties we contract with and to the subjects of a registry engagement. It is not a service we sell as an opinion on a third party.

§ 3What we refuse to hold

• No security, military, or armed-actor layer, in any form, anywhere in the system — not published, not internal, not for a customer who asks.
• No personal data products, and no data about private individuals as such.
• No brokerage, no introductions for a fee, no success fees and no commissions on any transaction we report on.
• No material obtained by circumventing a login or a paywall, and nothing leaked or unlawfully obtained, from any party.

§ 4How we collect

Public pages only. Robots directives are respected, requests are rate-limited, and our crawler identifies itself and publishes a contact address for complaints. Stored snapshots exist so a claim can be re-checked internally, and are never republished as article text; a public output shows the fact, the attribution and a link.

§ 5The operating entity

The operating company is not yet formed. When it is, this page will name it, name its jurisdiction of incorporation and its governing law, and carry its registration number. We would rather publish that absence than imply a corporate identity that does not exist, and a reader can hold us to filling it in.