The agreement requires both parties to comply with applicable export control laws and sanctions programs, including EAR, ITAR, and OFAC. Customers bear sole responsibility for export compliance related to how they use AWS services, including content transfer, processing, and region selection. Customers also represent and warrant that they and their financial institutions are not on any prohibited party lists maintained by the UN, U.S. government, EU, or member states.
This analysis describes what AWS'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
The provision places sole responsibility for export control compliance on the customer for their specific use of AWS services, including content and workload characteristics, and requires affirmative representation that the customer and its financial institutions are not subject to sanctions. Violation of export control representations could constitute a material breach triggering immediate termination under Section 5.2(b)(ii).
Under Section 11.6, customers affirmatively represent that they and their financial institutions are not subject to sanctions or listed on prohibited party lists, and assume sole responsibility for ensuring their use of AWS services complies with applicable export control and sanctions regulations. Breach of these representations may constitute grounds for immediate suspension or termination under Sections 4.1 and 5.2(b)(ii).
Cross-platform context
See how other platforms handle Export Controls and Sanctions Compliance and similar clauses.
Compare across platforms →"In connection with this Agreement, each party will comply with all applicable import, re-import, sanctions, anti-boycott, export, and re-export control laws and regulations, including all such laws and regulations that apply to a U.S. company, such as the Export Administration Regulations, the International Traffic in Arms Regulations, and economic sanctions programs implemented by the Office of Foreign Assets Control. For clarity, you are solely responsible for compliance related to the manner in which you choose to use the Services or AWS Content, including your transfer and processing of Your Content, the provision of Your Content to End Users, and the AWS region in which any of the foregoing occur.Excerpt from AWS's Customer Agreement
1.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
The provision places sole responsibility for export control compliance on the customer for their specific use of AWS services, including content and workload characteristics, and requires affirmative representation that the customer and its financial institutions are not subject to sanctions. Violation of export control representations could constitute a material breach triggering immediate termination under Section 5.2(b)(ii).
Under Section 11.6, customers affirmatively represent that they and their financial institutions are not subject to sanctions or listed on prohibited party lists, and assume sole responsibility for ensuring their use of AWS services complies with applicable export control and sanctions regulations. Breach of these representations may constitute grounds for immediate suspension or termination under Sections 4.1 and 5.2(b)(ii).
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by AWS.