Amazon · AWS Acceptable Use Policy · View original document ↗

Export Control and Sanctions Compliance

High severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

AWS prohibits using its services in ways that violate US export control laws or economic sanctions, including those administered by OFAC.

This analysis describes what Amazon's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This clause places the compliance burden for export control and sanctions screening on the customer, meaning organizations using AWS to process, store, or transmit data or technology must independently verify their activities comply with EAR and OFAC requirements.

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 9, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 912 other provisions on other platforms.

Consumer impact (what this means for users)

Customers using AWS services in connection with cross-border technology transfer, foreign nationals, or dealings with sanctioned countries or entities bear responsibility for ensuring their use of AWS infrastructure does not violate US export controls or OFAC sanctions.

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▸ View Original Clause Language DOCUMENT RECORD
"
You may not use the Services in any manner that would violate applicable export control laws and regulations, including the Export Administration Regulations (EAR) and economic sanctions regulations administered by the U.S. Office of Foreign Assets Control (OFAC).

— Excerpt from Amazon's AWS Acceptable Use Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision explicitly engages the Export Administration Regulations (15 C.F.R. Parts 730-774) administered by the Bureau of Industry and Security (BIS) and OFAC economic sanctions programs. Relevant enforcement authorities include BIS, OFAC, and the Department of Justice. Non-compliance can result in civil and criminal penalties. EU dual-use export controls under Regulation (EU) 2021/821 may also apply for EU-based customers. (2) GOVERNANCE EXPOSURE: High for organizations operating internationally or involving foreign nationals in AWS-hosted activities. Export control compliance for cloud-hosted technology and data transfers is a complex area; the AUP's placement of this obligation on the customer means AWS is not accepting responsibility for screening customer workloads for export control compliance. (3) JURISDICTION FLAGS: US-person obligations under OFAC apply globally to US persons regardless of where AWS infrastructure is located. EU customers must assess EU dual-use export regulations independently. UK customers are subject to the UK Export Control Order and OFAC-equivalent UK financial sanctions regimes. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise agreements with AWS may include additional export control representations and warranties. Organizations providing technology services to foreign entities through AWS infrastructure should conduct export control classification assessments and license determinations. Procurement teams onboarding AWS as a vendor for government or defense-adjacent contracts should include EAR and OFAC compliance verification. (5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should assess whether their AWS-hosted technology, software, or data falls within EAR-controlled categories. Organizations should implement OFAC screening procedures for customers, users, and counterparties accessing AWS-hosted services. Cross-border data transfer configurations should be reviewed for export control implications, particularly for encryption technology and controlled technical data.

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Applicable agencies

  • FTC
    The FTC may have jurisdiction over consumer protection aspects of undisclosed export control restrictions, though BIS and OFAC are the primary enforcement authorities for the underlying regulations
    File a complaint →

Applicable regulations

FTC Act Section 5
United States Federal

Provision details

Document information
Document
AWS Acceptable Use Policy
Entity
Amazon
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
May 12, 2026
Record ID
CA-P-002551
Document ID
CA-D-00028
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
35a0e34b7136e83dd0dca01e14dd192b01d7012211f2617232fe3d1a27218091
Analysis generated
April 27, 2026 10:50 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Amazon
Document: AWS Acceptable Use Policy
Record ID: CA-P-002551
Captured: 2026-04-27 10:50:37 UTC
SHA-256: 35a0e34b7136e83d…
URL: https://conductatlas.com/platform/amazon/aws-acceptable-use-policy/export-control-and-sanctions-compliance/
Accessed: June 17, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Amazon's Export Control and Sanctions Compliance clause do?

This clause places the compliance burden for export control and sanctions screening on the customer, meaning organizations using AWS to process, store, or transmit data or technology must independently verify their activities comply with EAR and OFAC requirements.

How does this clause affect you?

Customers using AWS services in connection with cross-border technology transfer, foreign nationals, or dealings with sanctioned countries or entities bear responsibility for ensuring their use of AWS infrastructure does not violate US export controls or OFAC sanctions.

Is ConductAtlas affiliated with Amazon?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Amazon.