As an international service provider, we operate globally and provide our Services to customers all over the world. Therefore, it is of utmost importance for us to comply with economic sanctions and trade embargoes imposed by the domestic, supranational and international bodies and authorities, such as those of the European Union and the United Nations. Compliance with the EU and the UN sanction regimes is a non-derogable obligation; however, due to the operation in other countries that are not Member States of the EU, we make sure to pay specific attention to the sanctions implemented by other regimes, such as the Office of Foreign Assets Control (the “OFAC”) of the US Department of Treasury, His Majesty’s Treasury Sanctions of the United Kingdom, as well as other sanction regimes.
In accordance with our Terms of Service, you shall be solely responsible for compliance with the Sanctions Policy as well as the economic sanctions and trade embargoes implemented, inter alia, by the European Union and the United Nations. Please note that we do not offer our Services to persons, whether natural or legal, that are subject to any applicable sanctions and/or embargoes, and we will not engage in any form of cooperation with or provision of our Services to such persons. In addition, we refuse to provide our Services to persons seeking to use our Services for the purposes of circumventing or violating any international, supranational or domestic sanctions, and will refuse cooperation with or provision of Services to any person who we reasonably suspect in conducting or attempting to conduct the aforementioned practices.
Information on all sanctions and embargo regimes and their applicability me be found via links below:
- European Union sanctions: EU Sanctions Map
- United States sanctions: OFAC
- United Kingdom sanctions
- UN sanctions
You shall familiarize yourself with the respective sanctions applicable to each sanctioned jurisdiction before selling or supplying your products, goods and services to such jurisdictions.
The following non-exhaustive list of activities serves as an example of practices, activities and business operations that will result in our refusal to provide our Services to you on the ground of violation and/or circumvention of sanctions.
- In regards to sanctions adopted following Russia’s military aggression against Ukraine:
a. Sale, supply, offer, transfer, export, market or otherwise making available to any person residing in Russia of any and all goods, services, products, materials and equipment subject to prohibitions and restrictions in accordance with Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine as well as Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for the purposes of import to, export from and transit through Russia as well as supply and sale to individuals and entities subject to the aforementioned sanctions and asset freeze.
b. Import from Russia of goods and products the sale of which generates significant revenue for Russia in accordance with Annex XXI to Article 3i of Council Regulation 833/2014;
c. Import of goods and products originating from Crimea, Sevastopol, Donetsk and Luhansk regions;
d. Export to Russia of goods and products classified as luxury goods un accordance with Annex XVIII to Article 3h of Council Regulation 833/2014, as well as other goods falling under Annex XXIII of Council Regulation 833/2014 regardless of their value;
e. Export to Russia and Belarus of dual-use goods and technologies, including goods containing such goods and technologies, as identified in Annex I of the EU Dual-Use Regulation, regardless of their use; - In regards to sanctions adopted following Belarus’ involvement in Russia’s military aggression against Ukraine:
a. Sale, supply, offer, transfer, export, market or otherwise making available to any person residing in Belarus of any and all goods subject to prohibitions and restrictions in accordance with Council Decision 2012/642/CFSP of 15 October 2012 concerning restrictive measures against Belarus and any transactions involving persons mentioned in the Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus; - In regards to sanctions against DPRK – North Korea, any and all transactions and acts involving goods and products subject to the ongoing regime of restrictive measures, involving sale, supply, import of goods from and sale to any individual or entity located and/or operating in the DPRK – North Korea;
- In regards to sanctions against Iran:
a. Export of arms, dual-use goods and goods used in enrichment-related activities;
b. Import of crude oil, natural gas, certain chemical products;
c. Sale and supply of key equipment used in the energy sector;
d. Sale and supply of gold, diamonds and other precious metals,
e. Sale and supply of equipment that might be used for internal repression and of equipment for monitoring telecommunications. - Any and all transactions involving individuals and entities on the EU and UN sanctions
Please note that the above-mentioned list of sanctions and trade embargoes is non-exhaustive and you shall familiarize yourself with legal acts implementing sanctions as well as other materials and/or seek legal counsel before engaging in trade with sanctioned jurisdictions and countries.
If we suspect that you operate from one of the above-mentioned countries or engage in prohibited trade with the sanctioned and embargoed jurisdictions, we may, in our sole discretion, suspend or terminate provision of our Services to you. We may, additionally, request you to provide documentation and information disclosing the details of the country of destination of your goods, services and products, origin of listed products as well as other information crucial for identification of potential violation or circumvention of sanctions.
We reserve the unequivocal right to terminate the customer relationship with immediate effect if we have reasonable grounds to believe or suspect that the customer is in violation of any international, supranational, or domestic sanctions, embargoes, or restrictive measures imposed by competent authorities. In the event of any such suspicion or belief, we are committed to reporting the matter to the relevant authorities, including but not limited to government agencies, regulatory bodies, and law enforcement agencies.
You shall be aware at all times that sanctions and embargoes are subject to constant change. In addition, countries may impose their own national sanction regimes and embargoes, such as, for instance, sanctions implemented by the Office of Foreign Assets Control (the “OFAC”) of the US Department of Treasury and His Majesty’s Treasury Sanctions of the UK. We do not, by any means and in any manner, control nor rule over the implementation, adoption or exemption of and from sanctions and you should consult qualified professionals before selling and supplying your goods, services and products to certain countries.
Finally, you shall be aware that some of our third-party partners and processors monitor compliance with the implementation of sanctions on their own behalf and at their own discretion. Any decision-making arising from terminating a business relationship with you and provision of services to you by such third parties remains with these third parties and are not controlled and/or influenced by us.
We encourage you to get acquainted with various resources concerning sanctions and their implementation, such as those listed below:
