Terms of Service

1. Agreement to terms

By accessing or using the Embargo service (“Service”) operated by Pintu Holdings Ltd, registered in England and Wales (“Company”, “we”, “us”), you agree to be bound by these Terms of Service (“Terms”). If you are using the Service on behalf of an organisation, you represent that you have authority to bind that organisation to these Terms.

If you do not agree to these Terms, do not use the Service.

The Service is intended primarily for organisations and people acting in the course of business. If you use it as a consumer, nothing in these Terms excludes rights that cannot lawfully be excluded.

2. The Service

Embargo is a regulatory intelligence and compliance screening platform. The Service currently covers 10 regulatory jurisdictions: the United States (BIS Entity List, OFAC Specially Designated Nationals, Federal Register / EAR rules and BIS notices), the European Union (Official Journal dual-use regulation and sanctions), the United Kingdom (ECJU export control notices and OFSI financial sanctions), the Netherlands (MOCIT advanced equipment controls), Japan (METI FEFTA semiconductor controls), Germany (BAFA export control circulars), and the United Nations (Security Council Consolidated List).

The Service includes:

• ▸Screening decision workspace — Organization-scoped review notes, evidence references, and analyst decisions with a preserved revision history. On-demand Gemini outlines quote saved public evidence and remain advisory until reviewed by an analyst.
• ▸Entity registry — A searchable registry of sanctioned, restricted, and watchlisted parties assembled from supported government sources on source-specific refresh schedules.
• ▸UK and US source record discovery — Search individual UK Sanctions List and US Consolidated Screening List records with full source names, aliases, list identifiers and evidence. Separate source records stay separate; discovery does not complete a counterparty screen.
• ▸Saved UK and US source name checks — Where enabled, retain selected UK/US source observations and review each matching record separately, with preserved evidence and analyst revision history. These name checks do not issue complete screening, clearance, certificates or monitoring.
• ▸Bulk CSV screening — Upload up to 500 entity names for batch screening across all monitored jurisdictions in a single operation.
• ▸Counterparty watchlist monitoring — Continuous re-screening of saved counterparties after registry updates, with notifications when a new match or status change is detected and processed.
• ▸Ownership chain resolution — Source-linked parent and affiliate evidence where reliable data is available. Unresolved relationships and inferred leads are identified for review rather than treated as legal conclusions.
• ▸AI entity intelligence notes — Source-grounded summaries of designation context, sector exposure, and supply chain risk generated with Google Gemini for registry entities where sufficient evidence is available.
• ▸Compliance audit trail — Timestamped records of all screening activity — bulk sessions, automated re-screens, and per-name outcomes — with exportable evidence reports.
• ▸Slack integration — Delivery of processed regulatory alerts to a configured Slack channel through an incoming webhook.
• ▸The Embargo Brief — A weekly analyst-written intelligence publication covering regulatory developments relevant to export compliance teams.

The Service is an information and monitoring service only. It does not constitute legal, regulatory, compliance, or professional advice of any kind.

3. Subscriptions and billing

4. Acceptable use

You agree not to:

• ▸Resell, sublicense, or redistribute the Service or its content without written permission.
• ▸Scrape, systematically download, or attempt to extract our entity registry or alert database in bulk.
• ▸Use the Service to build a competing product.
• ▸Attempt to circumvent authentication, access controls, rate limits, or security measures.
• ▸Share your account credentials with users outside your licensed seat count.
• ▸Upload or transmit malicious code, spam, or unlawful content.
• ▸Use the Service for any purpose that violates applicable law.

5. No legal or compliance advice

6. Intellectual property

The Embargo platform, brand, software, and original content are owned by Pintu Holdings Ltd and protected by copyright, trademark, and other intellectual property laws. Third-party and public-authority material remains subject to its applicable rights, notices, attribution requirements, and source terms. Embargo does not claim ownership of that source material merely because it is indexed or displayed through the Service.

Your organisation's data — including account settings, watchlist entries, screening history, and ECCN product profiles — remains your property. We do not claim ownership of any data you input into the Service.

7. Availability and accuracy

We aim for high availability but do not guarantee uninterrupted access. Regulatory monitoring is dependent on third-party data sources that may experience outages or delays. We make no warranty that:

• ▸Every regulatory update will be captured immediately upon publication.
• ▸AI-generated summaries, entity intelligence notes, or ownership inferences are free from errors or omissions.
• ▸The entity registry is exhaustive — it reflects the sources we monitor and may not capture all restricted parties globally.
• ▸The Service will be available at any particular time or location.

8. Limitation of liability

To the maximum extent permitted by applicable law, Pintu Holdings Ltd shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to:

• ▸Loss of profits or revenue
• ▸Regulatory penalties, fines, or compliance failures arising from reliance on the Service
• ▸Loss of data or business interruption

Our total aggregate liability to you in any 12-month period shall not exceed the greater of (a) the fees paid by you to us in that period or (b) £100 GBP.

9. Termination

We reserve the right to suspend or terminate your access to the Service immediately if you breach these Terms. You may terminate your subscription at any time. On termination, your right to use the Service ceases. Personal data is then handled under the retention and deletion criteria in our Privacy Policy; termination does not require deletion of records we lawfully need to preserve.

10. Governing law and disputes

These Terms are governed by and construed in accordance with the laws of England and Wales. Any disputes arising from these Terms or the Service shall be subject to the exclusive jurisdiction of the courts of England and Wales, except where mandatory consumer law gives you a right to bring proceedings elsewhere.

11. Changes to these terms

We may update these Terms from time to time. The date at the top identifies the version currently in effect. Where a material change affects existing registered users, we will notify them before it takes effect where reasonably practicable or where applicable law requires notice.

12. Contact