DRAFT v0.1 — 19 August 2026 — prepared for review by qualified counsel; not yet in force.
Key points (summary only — not binding; the numbered clauses prevail)
- Every account, listing and Deal on the Platform is subject to sanctions screening (OFAC, EU, UN, UK OFSI and other lists) — at onboarding, periodically, and again before each Deal. Potential matches put the account or Deal on hold until resolved.
- Aircraft parts are frequently subject to export controls. Sellers must classify their items (for example ECCN or EAR99 under the US EAR, or an EU dual-use entry) and declare controlled status in the listing.
- ITAR-controlled items (USML Category VIII and related) are prohibited on the Platform unless the ITAR module is separately enabled for both parties and all required licences are in place.
- Buyers are responsible for end-use and end-user statements, for obtaining any required licences, and for not diverting material to restricted destinations, denied parties or prohibited end-uses.
- Deals involving comprehensively sanctioned territories ([PLACEHOLDER LIST — e.g. the territories comprehensively sanctioned by OFAC from time to time]) or denied parties are refused.
- Vistason may hold funds, suspend or cancel Deals, block shipments, terminate accounts and report to authorities where this Policy or the law requires.
- Dangerous goods must be declared and shipped per IATA DGR, ADR or IMDG, as applicable.
- Records relevant to export compliance are kept for at least [5] years. Questions: [compliance@vistason.com].
1. Purpose and scope
1.1 This Export Control and Sanctions Policy (the "Policy") sets out the trade-compliance rules that apply to the Vistason Platform, operated by PostReach AI Limited ("Vistason"). Aviation parts, engines, components, tooling and related technical data are among the most heavily regulated goods in international trade. This Policy exists to keep the Platform, its users and their Deals within the law.
1.2 This Policy applies to: (a) every account, whether acting as Seller or Buyer, and every Authorised User; (b) every listing, offer, counter-offer, tender, bid and Deal; (c) every shipment, transfer or release of material or technical data arranged in connection with a Deal, including through third-party freight forwarders; and (d) Vistason itself, its staff and contractors. It forms part of the Vistason Terms of Service (the "Terms") and must be read with the Acceptable Use Policy, the Settlement and Payments Terms, the KYC/AML Policy and the Dispute Resolution and Returns Policy. Capitalised terms not defined here have the meaning given in the Terms.
1.3 Nothing in this Policy is legal advice, and compliance with this Policy does not replace your own obligations under applicable law. Each Seller and Buyer remains independently responsible for complying with all export-control, sanctions, customs and related laws that apply to it and to its transactions.
2. Sanctions screening
2.1 Lists screened. Vistason and its screening providers screen users and their related parties against, at a minimum: (a) the US OFAC Specially Designated Nationals (SDN) List and the OFAC Consolidated Sanctions List; (b) the EU Consolidated List of persons, groups and entities subject to EU financial sanctions; (c) the UN Security Council Consolidated List; (d) the UK OFSI Consolidated List of financial sanctions targets; and (e) such other national or sectoral lists (including denied-party, debarment and export-restriction lists such as the US Entity List, Denied Persons List and Unverified List) as Vistason considers relevant to the Platform ([ADDITIONAL LISTS]).
2.2 Who and what is screened. Screening covers the account entity; its directors, Authorised Users and ultimate beneficial owners identified under the KYC/AML Policy; the counterparty to each Deal; and, where disclosed or known, consignees, end-users, freight forwarders, ship-to addresses, banks and vessels or aircraft involved in delivery.
2.3 When screening occurs. Screening is performed: (a) at onboarding, before an account is activated; (b) periodically thereafter, including when the underlying lists are updated; and (c) before each Deal — at acceptance or award, before funds are accepted into the Settlement Account, and again before shipment is authorised and before the Settlement Funds are released, where circumstances have changed.
2.4 Potential matches. A potential match does not necessarily mean you are a sanctioned party; names recur. Where screening produces a potential match, the affected account, listing or Deal is placed on hold and no funds are accepted, released or refunded, and no shipment may proceed, until the match is resolved. Vistason may request additional identifying information (for example dates of incorporation, registration numbers, ownership evidence) and you must provide it promptly. If the match is confirmed, or cannot be resolved within a reasonable time, Vistason will refuse or terminate the relationship or Deal and act as clause 8 and applicable law require, including where the law requires it to freeze funds or refuse to return them.
2.5 Ownership and control. Sanctions rules extend to entities owned or controlled by sanctioned persons (for example OFAC's 50% rule and the equivalent EU and UK concepts). You must disclose your ownership structure truthfully under the KYC/AML Policy and notify Vistason without delay if any owner, director or controller of your entity becomes a sanctioned or denied party.
2.6 Refusal. Vistason refuses, and will not process, any account, listing or Deal that involves a sanctioned or denied party, that is prohibited by applicable sanctions, or that Vistason reasonably believes is structured to evade sanctions.
3. Export controls — overview
3.1 Aviation material and related technical data may be controlled under one or more regimes at the same time, depending on origin, content, destination, end-user and end-use. The regimes most relevant to the Platform are described in clauses 3.2 to 3.6. Other national regimes (for example those of the country of the Seller, the Buyer, the material's location or its origin) may also apply, and the parties must comply with them.
3.2 US Export Administration Regulations (EAR). Many civil aircraft parts are subject to the EAR because they are US-origin, incorporate more than a de minimis level of US content, or are located in or transiting the United States. Items subject to the EAR carry an Export Control Classification Number (ECCN) on the Commerce Control List or are designated EAR99. Classification determines whether a licence from the US Bureau of Industry and Security is needed for a given destination, end-user or end-use. Important: the EAR follows the item — re-exports and in-country transfers of US-origin items from outside the United States remain subject to the EAR, even between two non-US parties. The EAR also contains end-user and end-use restrictions (of the kind set out in Part 744 of the EAR) that can prohibit or condition a transaction with otherwise uncontrolled EAR99 items — for example military end-uses or end-users in certain countries, and listed parties. These descriptions are generic; the parties must apply the current regulations to their own transaction.
3.3 ITAR / USML Category VIII. Defence articles and defence services controlled under the US International Traffic in Arms Regulations (ITAR), including aircraft and related articles in Category VIII of the United States Munitions List and ITAR-controlled technical data, are prohibited on the Platform. They may not be listed, offered, sold or shipped through the Platform unless Vistason has separately enabled ITAR handling for both parties in writing, both parties hold all required registrations and licences (or valid exemptions), and the Deal is conducted in accordance with those authorisations. Attempting to list or trade ITAR-controlled material without such enablement is a material breach of the Terms. If a Seller is unsure whether an item is ITAR-controlled (for example a part with military provenance or a dual civil/military application), the Seller must resolve the question before listing.
3.4 EU Dual-Use Regulation. Exports from the EU of dual-use items listed in Annex I of Regulation (EU) 2021/821 require authorisation, and the Regulation's catch-all provisions can require authorisation for unlisted items in connection with certain end-uses or end-users. National lists and national controls of EU Member States may impose additional requirements, including on brokering and transit.
3.5 UK strategic export controls. Exports from the UK are subject to the UK Strategic Export Control Lists and the Export Control Order and related legislation, administered by the Export Control Joint Unit, including military, dual-use and catch-all controls.
3.6 Other regimes. Other countries operate their own export-control and import-control regimes. Where material is located in, originates from, transits or is destined for such a country, the applicable regime must be complied with. Anti-circumvention rules (including those targeting re-export to sanctioned destinations through third countries) apply.
4. Seller duties
4.1 Classify. Before listing, the Seller must determine the export-control status of each item and of any technical data offered with it: at minimum, whether the item is subject to the EAR and its ECCN or EAR99 designation where applicable; whether it is or may be ITAR-controlled (in which case clause 3.3 applies); and whether it is listed under the EU dual-use, UK strategic or other applicable control lists.
4.2 Declare. The Seller must record the export classification in the listing fields provided, declare any controlled status, military provenance or known licence requirements, and keep the declaration accurate for the life of the listing. "Unknown" is not an acceptable long-term classification for controlled-risk items; Vistason may unpublish listings with missing or implausible classifications.
4.3 Technical data. The Seller may upload or share manuals, drawings, test data or other technical data through the Platform or the Deal room only to the extent that the sharing is permitted without a licence, or the Seller holds the required licence covering each recipient. Export-controlled technical data must not be placed in listing fields visible to all users.
4.4 Shipment. The Seller (or the party responsible for export clearance under the applicable Incoterms rule) must obtain all required export licences and file all required export declarations before shipment, and must not ship while a Deal is on compliance hold.
4.5 Truthful provenance. The Seller must disclose known origin and provenance information relevant to export control (for example US origin, military removal, government surplus source) and must not misdescribe an item to avoid controls.
5. Buyer duties
5.1 End-use and end-user statements. The Buyer must, on request by Vistason, the Seller or the [PAYMENT SERVICES PROVIDER], provide a signed end-use and end-user statement identifying the intended end-user, end-use, and country of ultimate destination, in the form provided by Vistason or another form acceptable to the requesting party. A Deal may be conditioned on receipt of a satisfactory statement.
5.2 No diversion. The Buyer must not re-export, re-sell, transfer or otherwise divert material or technical data acquired through the Platform contrary to applicable export-control or sanctions law, including to restricted destinations, denied parties or prohibited end-uses (including military end-uses where restricted, and missile, nuclear, or chemical/biological weapons applications). The Buyer must flow down substantially equivalent restrictions to its own customers where required by law.
5.3 Licences. Unless the parties agree otherwise in the Deal, the Buyer is responsible for import licences and for any re-export authorisations it needs for its own onward activities; the party responsible for export clearance under the applicable Incoterms rule is responsible for the export licence. Neither party may treat the grant of a licence as guaranteed; a Deal that cannot lawfully be performed is handled under clause 8.
5.4 Destination accuracy. The Buyer must state the true country of ultimate destination and consignee and must not use intermediate consignees, freight forwarders or free-trade zones to obscure the real destination or end-user.
6. Restricted destinations and parties
6.1 Comprehensively sanctioned territories. Deals involving a party, consignee, end-user or destination in, or the transit (other than lawful transit) of, the following territories are refused: [PLACEHOLDER LIST — the territories subject to comprehensive sanctions from time to time under OFAC, EU, UN and UK regimes]. Vistason maintains the current list in the Platform's compliance pages and may update it as sanctions change.
6.2 Denied and restricted parties. Deals involving persons on the lists in clause 2.1, or entities owned or controlled by them, are refused. Deals involving parties on export-restriction lists (for example the US Entity List) may be refused or made conditional on evidence of licences.
6.3 Military end-use and end-user concerns. Vistason may refuse, hold or condition Deals where the known or suspected end-use or end-user raises military end-use concerns in destinations where such transactions are restricted, or where the Deal pattern otherwise raises diversion risk (for example a civil part in a quantity or configuration inconsistent with civil use, or a consignee with no plausible aviation activity).
6.4 Country risk settings. Vistason may apply enhanced review, additional documentation requirements or transaction limits to destinations and parties it rates as elevated risk, as also described in the KYC/AML Policy.
7. Dangerous goods and hazardous materials
7.1 The Seller must identify and declare dangerous goods and hazardous materials in the listing (for example chemical oxygen generators, squibs and other explosives, batteries, compressed gases, radioactive components such as certain instruments, magnetised material, and parts containing hazardous substances), including UN number and class where known.
7.2 Dangerous goods must be packed, marked, labelled, documented and tendered for transport in accordance with the applicable modal rules — the IATA Dangerous Goods Regulations for air, ADR for European road, and the IMDG Code for sea — and applicable national law, by personnel qualified to do so. The party arranging transport is responsible for compliance; the Seller is responsible for accurate declaration to the carrier and forwarder.
7.3 Undeclared or misdeclared dangerous goods are a serious safety violation and a material breach of the Terms; Vistason may cancel the Deal, hold funds, notify carriers and authorities where required, and terminate the account.
8. Vistason's rights and actions
8.1 Where Vistason reasonably believes that an account, listing, Deal or shipment may breach this Policy or applicable sanctions or export-control law, or where a screening hold under clause 2.4 applies, Vistason may, without liability to Seller or Buyer: (a) suspend or unpublish listings; (b) place a Deal on hold, withhold release of the Settlement Funds and instruct the [PAYMENT SERVICES PROVIDER] accordingly, under the Settlement and Payments Terms; (c) cancel a Deal; (d) block or instruct the blocking of a shipment arranged through Platform-introduced forwarders, and notify other involved carriers or forwarders; (e) require additional documents, statements or licences before proceeding; (f) suspend or terminate accounts under the Terms; and (g) make reports to competent authorities.
8.2 Where applicable law requires funds or assets to be frozen or blocked, Vistason and the [PAYMENT SERVICES PROVIDER] will comply, and neither is liable for the consequences of doing so, including inability to release or return funds.
8.3 Vistason may (and in some cases must) report suspected violations to competent authorities, including OFAC, BIS, national export-control and customs authorities, and financial-intelligence units, and may do so without notice to you where notice is prohibited or would prejudice an investigation.
8.4 Vistason's screening, holds and reviews are risk controls for the Platform. They are not legal advice, a classification service, or a guarantee that a Deal is lawful, and they do not transfer the parties' own compliance responsibilities to Vistason.
9. Anti-boycott
9.1 Users must not use the Platform to further any boycott not sanctioned by the United States or by the law of the user's own jurisdiction, including by requesting or supplying boycott-related declarations, or refusing to deal on prohibited boycott grounds. Boycott-related requests received through the Platform must be reported to [compliance@vistason.com], and users remain responsible for their own reporting obligations (for example under US anti-boycott rules).
10. Record keeping
10.1 Each Seller and Buyer must keep records demonstrating export-control and sanctions compliance for its Deals — classifications, licences and licence exceptions relied on, end-use and end-user statements, screening evidence, shipping and customs documents — for at least [5] years from the relevant transaction, or longer where the law requires.
10.2 Vistason keeps its own records of screening, classifications declared, compliance holds, decisions and instructions for at least [5] years, and transaction records for [10] years, as described in the Privacy Policy.
11. Training, contact and cooperation
11.1 Vistason maintains internal procedures and training for staff who operate onboarding, screening and Deal compliance. Users must ensure that their Authorised Users who list, buy or ship through the Platform are adequately trained in the export-control and dangerous-goods obligations relevant to their role.
11.2 Questions, disclosures, licence documentation and reports of suspected violations should be sent to [compliance@vistason.com]. Users must cooperate promptly and truthfully with Vistason's compliance enquiries; failure to cooperate is itself grounds for suspension.
12. Penalties awareness
12.1 Violations of sanctions and export-control laws carry severe consequences independent of anything in this Policy: civil and criminal penalties for companies and individuals (including fines and imprisonment), denial of export privileges, debarment, seizure of goods and funds, and reputational damage. Breach of this Policy is also a material breach of the Terms and may result in cancellation of Deals, forfeiture of fees, termination of accounts and reporting to authorities.
13. Changes
13.1 Sanctions and export-control law changes quickly. Vistason may amend this Policy at any time with effect on posting to the Platform, and will give advance notice of material changes where reasonably practicable. Continued use of the Platform after a change takes effect constitutes acceptance. The version applicable to a Deal is the version in force when the Deal event concerned occurs.
13.2 This Policy is governed by the law of [SPAIN] as provided in the Terms, without prejudice to the mandatory application of the sanctions and export-control laws described above.