Legal Rights & Agreement Rules · Company commitment
Bloomberg commits to ethical conduct and legal compliance
Bloomberg states that it is committed to running its business at the highest ethical level and to complying with all applicable laws and regulations. It names anti-bribery and anti-corruption, anti-money laundering, human rights, tax evasion, sanctions and trade controls as examples of the laws it means. This is a statement of Bloomberg's own commitment; the notice does not attach a user remedy or a specific measure to it.
Supporting quotations
Bloomberg is committed to conducting its business at the highest ethical level and complying with all applicable laws and regulations, including those relating to anti-bribery/anti-corruption, anti-money laundering, human rights, tax evasion, sanctions and trade controls.
Qualifications & exceptions
The listed areas are introduced by "including", so they are examples, not a complete list of the laws covered.
Not stated here
The notice does not say how Bloomberg carries out or checks this commitment, or what a user can do if it is not met.
Legal Rights & Agreement Rules · Context
Bloomberg expects partners, suppliers and customers to act ethically and lawfully
Bloomberg says it expects its partners, suppliers and customers to conduct business ethically and in compliance with applicable laws and regulations. Customers are included in this expectation. The sentence states an expectation only; what follows if the expectation is not met is addressed in the separate statement about suspension and termination.
Supporting quotations
Bloomberg likewise expects its partners, suppliers and customers to conduct business in an ethical manner and in compliance with applicable laws and regulations.
Qualifications & exceptions
The sentence is worded as an expectation ("expects"), not as a rule or a listed requirement.
Not stated here
The notice does not define who counts as a partner, supplier or customer, or say whether it applies to individual consumer subscribers.
The sentence itself does not state a consequence for falling short.
Legal Rights & Agreement Rules · Restriction or exception
Using Bloomberg services for listed serious activities is strictly prohibited
The notice strictly prohibits using Bloomberg services in connection with activities relating to nuclear, chemical or biological weapons proliferation, terrorism (including financing of terrorism), corruption, undermining of democratic rights and government, money laundering, tax evasion or human rights violations. The ban also covers "other similarly egregious activities", so it is not limited to the listed items.
Supporting quotations
It is strictly prohibited to use Bloomberg services in connection with activities relating to nuclear, chemical or biological weapons proliferation, terrorism (including financing of terrorism), corruption, undermining of democratic rights and government, money laundering, tax evasion or human rights violations, or other similarly egregious activities
Qualifications & exceptions
The prohibition applies to use of "Bloomberg services" "in connection with" these activities.
"Other similarly egregious activities" extends the prohibition beyond the listed items.
Not stated here
The notice does not define "similarly egregious" or say who decides whether an activity is covered.
The notice does not say which Bloomberg services or customer types it applies to.
No exception or approval process appears in this notice.
Legal Rights & Agreement Rules · Restriction or exception
Using Bloomberg services in or for certain places is strictly prohibited
The same sentence strictly prohibits using Bloomberg services in, or for the benefit of, "the non-Ukraine-government controlled regions of Ukraine, Syria, Cuba, North Korea, or Iran". The ban is on use in those places and also on use for their benefit.
Supporting quotations
or in, or for the benefit of the non-Ukraine-government controlled regions of Ukraine, Syria, Cuba, North Korea, or Iran
Qualifications & exceptions
The prohibition covers use "in" the places and use "for the benefit of" them.
Not stated here
The notice does not name the specific regions of Ukraine.
The wording does not make clear whether "non-Ukraine-government controlled" qualifies only Ukraine or each place listed.
No exception or licence process appears in this notice.
Account & Service Control · Permission or license
Bloomberg may suspend or terminate a business relationship for legal or policy risk
Bloomberg reserves the right to suspend or terminate any business relationship, including the provision of services, in two situations. One is when the relationship violates applicable laws or regulations or presents the risk of violating them. The other is when it implicates activities or parties that do not comport with Bloomberg's policies and standards. A risk of violation is enough for the first; an actual violation is not required.
Supporting quotations
Bloomberg reserves the right to suspend or terminate any business relationship (including the provision of services) that violates or presents the risk of violating applicable laws or regulations or that implicates activities or parties not comporting with our policies and standards.
Qualifications & exceptions
Covers suspension as well as termination, and "any business relationship (including the provision of services)".
The first trigger includes a risk of violating laws or regulations, not only an actual violation.
Not stated here
The notice does not identify the "policies and standards" it refers to, and no linked policy text is supplied.
The notice does not say who determines that a violation or risk exists or what evidence is needed.
Account & Service Control · Company practice
Suspension or termination may have to happen immediately in some cases
The notice says that in certain instances Bloomberg may be required to suspend or terminate immediately. It does not say who or what imposes that requirement or which instances it means, so it should be read as a possibility that applies only in some cases, not as a general rule of immediate action.
Supporting quotations
In certain instances, Bloomberg may be required to do so immediately.
Qualifications & exceptions
The wording is "in certain instances" and "may be required", so immediate action is described as a possibility in some cases.
Not stated here
The notice does not say which instances call for immediate action or what requires it.
The notice does not say whether any prior warning is given in such cases.
Account & Service Control · Company commitment
Bloomberg will attempt to notify the client or counterparty within a reasonable time
Bloomberg says it will attempt to notify the client or counterparty of a suspension or termination within a reasonable time. The commitment is to attempt notice, not to guarantee that notice is given or received, and no deadline is stated.
Supporting quotations
Bloomberg will attempt to notify the client or counterparty of such suspension or termination within a reasonable time.
Qualifications & exceptions
The commitment is to "attempt" to notify, and the timing is "within a reasonable time".
Not stated here
The notice does not define a reasonable time or say how notice is given.
The notice does not say whether notice comes before or after the action, or whether a reason is included.
Legal Rights & Agreement Rules · Context
More information on compliance is on a linked page that is not supplied
The notice points to a Bloomberg web page for more information about its commitment to compliance and ethical business practices. That page is not part of the supplied text, so nothing from it is included in this analysis, and the notice does not say the page adds binding terms.
Supporting quotations
Information regarding Bloomberg’s commitment to compliance and to ethical business practices can be found [here](https://www.bloomberg.com/impact/).
Qualifications & exceptions
The link is described as a source of information about Bloomberg's commitment, not as part of the notice's rules.
Not stated here
The linked page was not supplied, so its content and any obligations it contains are unknown.