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Last substantive legal review: November 2026. This guide is general information, not legal advice. Export rules in this area change often. Confirm every classification and license decision against the current...
Secondary Sanctions Are Expanding: The Office of Foreign Assets Control (OFAC) is aggressively leveraging secondary sanctions, meaning foreign financial institutions (FFIs) can lose access to the US financial system even...
Extraterritorial Jurisdiction: International SaaS providers are subject to US export controls if their software contains US-origin technology, is hosted on US servers, or utilizes specific levels of encryption. Encryption Classifications:...
Non-US acquirers assume strict liability for historic sanctions breaches committed by US target entities or their foreign subsidiaries under OFAC enforcement rules. Voluntary Self-Disclosures (VSDs) routinely take 6 to 18...
Dual-regime exposure : OFAC regulates identity, geography, and financial rails. BIS regulates technical capability, software classification, and compute architecture. Physical borders do not limit cloud reach : Providing remote access...
If you build hardware, write software, or provide tech services outside the United States using US-origin parts, code, or tooling, US export controls follow those items onto foreign soil. The...