Risk Disclosures

1. General Risk Statement

Using the Archway platform ("Platform") involves managing, storing, and sharing sensitive corporate and personal documents with third-party counterparties. These activities carry risks. You should carefully consider whether using the Platform is appropriate given your organization's compliance requirements and risk tolerance.

The risks described below are not exhaustive. New risks may emerge as regulatory frameworks evolve. You should consult with qualified legal and compliance advisors before using the Platform.

2. Data Accuracy and Completeness Risks

• User-provided data: Archway stores and submits information that you provide. We do not independently verify the accuracy or completeness of entity profiles, ownership structures, or uploaded documents. Inaccurate data may result in counterparty rejections or compliance violations.
• Stale information: Corporate structures, beneficial ownership, and document validity change over time. While Archway provides expiry alerts and refresh reminders, it is your responsibility to keep your records current.
• Cross-entity sharing: Documents shared across multiple entities may become outdated for some entities while remaining current for others. Review cross-entity document linkages regularly.

3. AI and Automation Risks

• AI-generated answers: The Platform uses AI to classify documents, extract data, and generate answers for counterparty forms. AI outputs may be inaccurate, incomplete, or misattributed. All AI-generated content should be reviewed by a qualified human before submission.
• Confidence scores: Confidence scores are estimates, not guarantees. A high-confidence answer may still be incorrect. A low-confidence flag does not mean the answer is necessarily wrong.
• Document classification: Automated document classification may incorrectly identify document types, extract wrong metadata, or miss relevant information. Verify classifications before relying on them.
• Ownership graph construction: AI-constructed ownership and control graphs are proposals, not authoritative legal determinations. Analyst review and confirmation is required before using AI-generated structures in submissions.

4. Regulatory and Compliance Risks

• Evolving requirements: KYB requirements, beneficial ownership definitions, and regulatory frameworks vary by jurisdiction and change frequently. The Platform's jurisdiction rules and refresh schedules are informational and may not reflect the latest regulatory changes.
• Counterparty-specific rules: Each counterparty may have unique requirements beyond standard regulatory frameworks. The Platform's counterparty profiles and templates are best-effort and may not capture all requirements.
• Cross-border complexity: Multi-jurisdiction corporate structures involve overlapping and sometimes conflicting regulatory requirements. The Platform does not provide guidance on resolving regulatory conflicts.
• Data protection: Sharing personal documents (passports, proof of address) with counterparties is subject to GDPR and other data protection regulations. You are responsible for ensuring that sharing is lawful and that appropriate consent has been obtained.

5. Security and Data Risks

• Data breach: Despite encryption, access controls, and security measures, no system is completely secure. A breach could expose sensitive corporate or personal documents.
• Unauthorized access: Compromised account credentials, misconfigured RBAC permissions, or social engineering could result in unauthorized access to sensitive documents.
• AI provider data handling: Document content is processed by third-party AI providers for classification and extraction. While we require zero-training guarantees and data processing agreements, data is transmitted to external systems during processing.
• Shared document exposure: Documents submitted to counterparties via secure links or packets leave your direct control. Counterparties may retain, copy, or further share submitted documents.

6. Third-Party and Platform Risks

• Service availability: The Platform depends on cloud infrastructure, AI providers, and email services. Outages or degraded performance at any of these providers could affect your ability to access documents or complete submissions.
• Cross-tenant patterns: The Platform's quality advisor uses anonymized submission patterns from other tenants. These patterns are statistical observations, not guarantees. A pattern suggesting "counterparty X rejects docs older than 3 months" may not apply in all cases.
• Counterparty rejection: Even with complete, accurate, and timely submissions, counterparties may reject applications for reasons outside the Platform's control. Archway does not guarantee submission approval.

7. No Legal or Compliance Advice

Archway does not provide legal advice, compliance advice, tax advice, or regulatory guidance. Nothing on the Platform, in our communications, or in our documentation should be construed as professional advice or a substitute for consultation with qualified legal and compliance professionals.

Compliance calendar alerts, jurisdiction rules, refresh schedules, and AI-generated answers are informational tools, not authoritative compliance determinations. You are solely responsible for your organization's compliance obligations and should independently verify all information before acting on it.

8. Risk Acknowledgment

By using the Platform, you acknowledge that you have read and understood these risk disclosures. You accept that:

• Managing corporate identity documents and KYB submissions carries inherent risks, including the potential for data exposure, regulatory non-compliance, and counterparty rejection.
• AI-generated content requires human review and should not be relied upon as the sole basis for compliance decisions.
• You are solely responsible for the accuracy and completeness of information submitted through the Platform.
• Archway Global is not liable for losses resulting from the risks described herein, counterparty decisions, or regulatory actions.

9. Contact

If you have questions about these risk disclosures, please contact us at: [email protected]