MemGPT/example-sec-filings · Datasets at Hugging Face

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financing laws and regulations around the world, including the BSA.
Among other things, the BSA requires money services businesses
(including money transmitters such as Airbnb Payments) to develop and
implement risk-based anti-money laundering programs, report large cash
transactions and suspicious activity, and maintain transaction records.
The BSA prohibits, among other things, our involvement in transferring
the proceeds of criminal activities. In connection with and when
required by regulatory requirements, we make information available to
certain U.S. federal and state, as well as certain foreign, government
agencies to assist in the prevention of money laundering, terrorist
financing, and other illegal activities and pursuant to legal
obligations and authorizations. In certain circumstances, we may be
required by government agencies to deny transactions that may be related
to persons suspected of money laundering, terrorist financing, or other
illegal activities, and it is possible that we may inadvertently deny
transactions from customers who are making legal money transfers.
Regulators in the United States and globally may require us to further
revise or expand our compliance programs, including the procedures we
use to verify the identity of our customers and to monitor international
and domestic transactions. In the United Kingdom and European Union, the
implementation of further anti-money laundering requirements and
regulations may make compliance more costly and operationally difficult
to manage, lead to increased friction for customers, and result in a
decrease in business. Penalties for non-compliance with the European
Union' Fourth Anti-Money Laundering Directive ("LD4" could include fines
of up to 10% of APLux' total annual turnover. In April 2018, the
European Parliament adopted the European Commission' proposal for a
Fifth Anti-Money Laundering Directive ("LD5", which has now been
implemented in the national laws of EU Member States and which contains
more stringent provisions in certain areas, which will increase
compliance costs. Similar penalties are available to the UK Financial
Conduct Authority in relation to APUK pursuant to the UK' implementation
of the EU Money Laundering Directives in the Money Laundering, Terrorist
Financing and Transfer of Funds (Information on the Payer) Regulations
2017/692 (as amended).

*We are subject to governmental economic and trade sanctions laws and
regulations that limit the scope of our offering. Additionally, failure
to comply with applicable economic and trade sanctions laws and
regulations could subject us to liability and negatively affect our
business, results of operations and financial condition.*

We are required to comply with economic and trade sanctions administered
by governments where we operate, including agencies of the U.S.
government (including without limitation regulations administered and
enforced by OFAC, the U.S. Department of State, and the U.S. Commerce
Department), the Council of the European Union, the Office of Financial
Sanctions Implementation of His Majesty' Treasury in the United Kingdom
("FSI" and the Ministry of Finance and Commission de Surveillance du
Secteur Financier of Luxembourg. These economic and trade sanctions
generally prohibit or restrict transactions to or from or dealings with
certain specified countries, regions, governments and, in certain
circumstances, their nationals, and with individuals and entities that
are specially-designated, such as individuals and entities included on
OFAC' List of Specially Designated Nationals and Blocked Persons ("DN
List", subject to EU/UK asset freezes, or other sanctions measures. Any
future economic and trade sanctions imposed in jurisdictions where we
have significant business could materially adversely impact our
business, results of operations, and financial condition. Our ability to
track and verify transactions and otherwise to comply with these
regulations require a high level of internal controls. We maintain
policies and procedures to implement these internal controls, which we
periodically assess and update to the extent we identify compliance
gaps. We routinely report to OFAC on payments we have rejected or
blocked pursuant to OFAC sanctions regulations and on possible
violations of those regulations. We have also reported to OFSI on
dealings with persons subject to UK sanctions and to the Luxembourg
Ministry of Finance on dealings with persons subject to EU sanctions.
There is a risk that, despite the internal controls that we have in
place, we have engaged in transactions inconsistent with applicable
sanctions laws. Any non-compliance with economic and trade sanctions
laws and regulations or related investigations could result in claims or
actions against us and materially adversely affect our business, results
of operations, and financial condition. As our business continues to
grow and regulations change, we may be required to make additional
investments in our internal controls or modify our business.

As a result of Russia' military action in Ukraine in 2022, governmental
authorities in the United States, the European Union, and the United
Kingdom, among others, launched an expansion of coordinated sanctions
and export control measures, including sanctions against certain
individuals and entities and prohibiting or limiting certain financial
and commercial transactions. We had identified certain transactions that
potentially implicated those sanctions, we notified the appropriate
regulators about these developments, and OFAC initiated a civil
investigation of certain payment instructions involving attempted
payouts to Hosts\' bank accounts at sanctioned Russian banks. In August
2022, OFAC closed the investigation by issuing a cautionary letter with
no administrative penalty.

*We are subject to payment network rules and any material modification
of our payment card acceptance privileges could have a material adverse
effect on our business, results of operations, and financial condition.*

The loss of our credit and debit card acceptance privileges or the
significant modification of the terms under which we obtain card
acceptance privileges would significantly limit our business model since
a vast majority of our guests pay using credit or debit cards. We are
required by our payment processors to comply with payment card network
operating rules, including the Payment Card Industry Data Security

financing laws and regulations around the world, including the BSA.

Among other things, the BSA requires money services businesses

(including money transmitters such as Airbnb Payments) to develop and

implement risk-based anti-money laundering programs, report large cash

transactions and suspicious activity, and maintain transaction records.

The BSA prohibits, among other things, our involvement in transferring

the proceeds of criminal activities. In connection with and when

required by regulatory requirements, we make information available to

certain U.S. federal and state, as well as certain foreign, government

agencies to assist in the prevention of money laundering, terrorist

financing, and other illegal activities and pursuant to legal

obligations and authorizations. In certain circumstances, we may be

required by government agencies to deny transactions that may be related

to persons suspected of money laundering, terrorist financing, or other

illegal activities, and it is possible that we may inadvertently deny

transactions from customers who are making legal money transfers.

Regulators in the United States and globally may require us to further

revise or expand our compliance programs, including the procedures we

use to verify the identity of our customers and to monitor international

and domestic transactions. In the United Kingdom and European Union, the

implementation of further anti-money laundering requirements and

regulations may make compliance more costly and operationally difficult

to manage, lead to increased friction for customers, and result in a

decrease in business. Penalties for non-compliance with the European

Union' Fourth Anti-Money Laundering Directive ("LD4" could include fines

of up to 10% of APLux' total annual turnover. In April 2018, the

European Parliament adopted the European Commission' proposal for a

Fifth Anti-Money Laundering Directive ("LD5", which has now been

implemented in the national laws of EU Member States and which contains

more stringent provisions in certain areas, which will increase

compliance costs. Similar penalties are available to the UK Financial

Conduct Authority in relation to APUK pursuant to the UK' implementation

of the EU Money Laundering Directives in the Money Laundering, Terrorist

Financing and Transfer of Funds (Information on the Payer) Regulations

2017/692 (as amended).

*We are subject to governmental economic and trade sanctions laws and

regulations that limit the scope of our offering. Additionally, failure

to comply with applicable economic and trade sanctions laws and

regulations could subject us to liability and negatively affect our

business, results of operations and financial condition.*

We are required to comply with economic and trade sanctions administered

by governments where we operate, including agencies of the U.S.

government (including without limitation regulations administered and

enforced by OFAC, the U.S. Department of State, and the U.S. Commerce

Department), the Council of the European Union, the Office of Financial

Sanctions Implementation of His Majesty' Treasury in the United Kingdom

("FSI" and the Ministry of Finance and Commission de Surveillance du

Secteur Financier of Luxembourg. These economic and trade sanctions

generally prohibit or restrict transactions to or from or dealings with

certain specified countries, regions, governments and, in certain

circumstances, their nationals, and with individuals and entities that

are specially-designated, such as individuals and entities included on

OFAC' List of Specially Designated Nationals and Blocked Persons ("DN

List", subject to EU/UK asset freezes, or other sanctions measures. Any

future economic and trade sanctions imposed in jurisdictions where we

have significant business could materially adversely impact our

business, results of operations, and financial condition. Our ability to

track and verify transactions and otherwise to comply with these

regulations require a high level of internal controls. We maintain

policies and procedures to implement these internal controls, which we

periodically assess and update to the extent we identify compliance

gaps. We routinely report to OFAC on payments we have rejected or

blocked pursuant to OFAC sanctions regulations and on possible

violations of those regulations. We have also reported to OFSI on

dealings with persons subject to UK sanctions and to the Luxembourg

Ministry of Finance on dealings with persons subject to EU sanctions.

There is a risk that, despite the internal controls that we have in

place, we have engaged in transactions inconsistent with applicable

sanctions laws. Any non-compliance with economic and trade sanctions

laws and regulations or related investigations could result in claims or

actions against us and materially adversely affect our business, results

of operations, and financial condition. As our business continues to

grow and regulations change, we may be required to make additional

investments in our internal controls or modify our business.

As a result of Russia' military action in Ukraine in 2022, governmental

authorities in the United States, the European Union, and the United

Kingdom, among others, launched an expansion of coordinated sanctions

and export control measures, including sanctions against certain

individuals and entities and prohibiting or limiting certain financial

and commercial transactions. We had identified certain transactions that

potentially implicated those sanctions, we notified the appropriate

regulators about these developments, and OFAC initiated a civil

investigation of certain payment instructions involving attempted

payouts to Hosts\' bank accounts at sanctioned Russian banks. In August

2022, OFAC closed the investigation by issuing a cautionary letter with

no administrative penalty.

*We are subject to payment network rules and any material modification

of our payment card acceptance privileges could have a material adverse

effect on our business, results of operations, and financial condition.*

The loss of our credit and debit card acceptance privileges or the

significant modification of the terms under which we obtain card

acceptance privileges would significantly limit our business model since

a vast majority of our guests pay using credit or debit cards. We are

required by our payment processors to comply with payment card network

operating rules, including the Payment Card Industry Data Security