Export Control, Sanctions & Anti-Corruption Policy

Aliff Solutions FZC is a company registered in the United Arab Emirates, that provides AI-powered intelligence tools and advisory services to government contractors operating primarily in the United States federal and SLED (State, Local, Education, Defense) markets.

Given our cross-jurisdictional operations, Aliff Solutions is committed to full compliance with applicable export control laws, economic sanctions regimes, and anti-corruption statutes. This policy governs our approach to these regulatory requirements.

ITAR (International Traffic in Arms Regulations): The Aliff Solutions platform is a commercial software service providing business intelligence and analytics. It is not designed to process, store, or transmit ITAR controlled technical data, defense articles, or defense services as defined under 22 CFR Parts 120-130.

EAR (Export Administration Regulations): Our platform is classified as a commercial SaaS offering. We do not knowingly process or store items, software, or technology controlled under the Commerce Control List (CCL) administered by the Bureau of Industry and Security (BIS).

Important limitation: Clients must not upload, transmit, or process ITAR-controlled technical data, CUI (Controlled Unclassified Information) marked as export-controlled, or any data subject to export control restrictions through the Aliff Solutions platform. The platform is not designed or authorized to handle such data.

If your organization handles ITAR-controlled data and needs to understand how our services intersect with your export compliance obligations, please contact us before onboarding.

The Aliff Solutions platform is not currently authorized to process, store, or transmit Controlled Unclassified Information (CUI) as defined by 32 CFR Part 2002 and NIST SP 800-171. Specifically:

• The platform does not hold CMMC (Cybersecurity Maturity Model Certification) authorization for our own systems
• The platform does not meet the requirements of NIST SP 800-171 for CUI handling
• Clients must not upload CUI-marked documents or data to the platform

Our compliance features (CMMC readiness tracking, NIST 800-171 control assessment) help clients track their own CUI handling compliance posture. These features do not imply that the Aliff Solutions platform itself is CUI-authorized.

We are transparent about this distinction because we believe accurate compliance representations are fundamental to trust in the GovCon market.

Aliff Solutions complies with applicable economic sanctions programs, including:

• U.S. OFAC sanctions: We do not provide services to individuals or entities on the Specially Designated Nationals (SDN) list maintained by the Office of Foreign Assets Control (OFAC)
• UAE sanctions: We comply with sanctions imposed by the UAE Executive Office of the Committee for Goods and Materials Subjected to Import and Export Control
• EU sanctions: We comply with restrictive measures adopted by the European Union where applicable to our operations

Screening: As part of our client onboarding process, we conduct due diligence on prospective clients to identify potential sanctions concerns. We reserve the right to decline or terminate service to any individual or entity that is subject to sanctions or where providing services would create sanctions risk.

As a UAE-registered entity serving the U.S. government contracting market, Aliff Solutions is committed to compliance with applicable anti-corruption laws, including:

• U.S. Foreign Corrupt Practices Act (FCPA): We do not make, offer, or authorize payments or gifts to foreign officials or government employees to obtain or retain business
• UK Bribery Act 2010: We maintain adequate procedures to prevent bribery and corruption in all business dealings
• UAE Federal Decree-Law No. 20 of 2018: We comply with UAE anti-money laundering and anti-terrorism financing regulations

Aliff Solutions does not act as an intermediary between clients and government agencies. Our role is to provide analytical tools and advisory services. We do not participate in procurement lobbying, campaign contributions, or any activities that could be construed as improper influence on government procurement decisions.

By using the Aliff Solutions platform, you represent and warrant that:

• You are not an individual or entity listed on any applicable sanctions list (OFAC SDN, EU Consolidated List, UK Sanctions List, or equivalent)
• You will not upload ITAR-controlled technical data, classified information, or export-controlled data to the platform
• You will not upload CUI-marked documents or data to the platform unless a specific written authorization has been agreed upon
• You will not use the platform to facilitate any corrupt practice, bribery, or improper influence on government procurement
• You will comply with all applicable export control, sanctions, and anti-corruption laws in your use of the platform

Violation of these obligations may result in immediate termination of your account and referral to appropriate authorities.

For questions about export control compliance, sanctions screening, or anti-corruption obligations, please contact us.

Entity: Aliff Solutions FZC, Ras Al Khaimah, United Arab Emirates