Coursera · Coursera Terms of Use · View original document ↗

Export Controls and Sanctions Compliance Warranty

Low severity High confidence Explicitdocumentlanguage Unique · 0 of 352 platforms
Get alerted the next time Coursera changes these terms. Get same-day alerts →
Share 𝕏 Share in Share 🔒 PDF
Recent governance activity Coursera recorded 2 documented changes in the last 30 days.
Get same-day alerts →
Monitor governance changes for Coursera Monitor emails you the same day this changes. The archive stays free.
Get same-day alerts →

Get the weekly 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. No account.

Document Record

What it is

Users warrant upon each use of the services that they are not located in or subject to a sanctioned country, not on any government sanctions or restricted party list, and not using VPN or IP routing services to circumvent these restrictions. Users must immediately discontinue service use if they are placed on a Sanctions List.

This analysis describes what Coursera'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 provision frames sanctions compliance as a user warranty that is confirmed upon each service use, and expressly prohibits VPN or IP routing circumvention of geographic restrictions. Coursera may terminate service immediately for sanctions compliance breaches or where continued service provision may cause commercial or reputational harm, at Coursera's sole discretion.

Recent Activity

This document changed recently

Medium Jul 3, 2026

The updated refund policy establishes a new condition under which Coursera may deny refund requests: when a significant portion of the course content has been accessed prior to submitting the refund request. This addition does not replace existing denial grounds such as policy violations, repeated refund requests, or chargeback activity, but adds an access-based threshold alongside them. The terms do not define what constitutes a significant portion of content, leaving that determination to Coursera's discretion. Learners who access substantial course materials before requesting a refund may find their request denied under this provision.

View change record →
Medium Jun 30, 2026

The updated terms establish new procedural requirements for refunds on Coursera subscription plans. According to the revised language, canceling a subscription will stop future billing but will not automatically issue a refund; refunds must be requested separately. The terms now explicitly state that refunds will not be provided for renewal charges on annual subscription plans. For Specializations purchased through subscriptions, users may request a full refund within the applicable 7-day refund period or before earning a certificate, whichever occurs first. You can request a refund separately through Coursera's Support Services, but the updated terms indicate this is a manual process rather than an automatic one upon cancellation.

View change record →
High May 27, 2026

The updated terms no longer specify refund eligibility for users in India who prepay for specializations or Coursera Plus plans. Previously, these customers could request full refunds within 7 days of payment or before earning a certificate for any course included in their purchase, whichever occurred first. The removal of this language means refund terms for Indian prepaid customers are no longer explicitly defined in the publicly stated agreement, leaving refund policies unclear for this user segment.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users in sanctioned countries or on government restricted party lists are prohibited from using the services, and use of VPN or IP routing services to circumvent geographic restrictions constitutes a terms violation. Users placed on a Sanctions List must immediately discontinue access, and Coursera may terminate service access unilaterally upon identifying a compliance risk.

Cross-platform context

See how other platforms handle Export Controls and Sanctions Compliance Warranty and similar clauses.

Compare across platforms →

Monitoring

Coursera has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.

Get Monitor Or create a free account →
▸ View Original Clause Language DOCUMENT RECORD
"
By using our Services, you are warranting that you are not located in, under the control of, a national of, or ordinarily resident in, any country that is subject to applicable U.S. laws and regulations, or laws of your local jurisdiction, preventing Coursera from providing you access to the Services. Your location is determined by your physical location. Use of a virtual private network service, IP routing services, or other similar service for the purpose of circumventing these laws is strictly prohibited. By using our Services, you are warranting that you are not named on, or controlled by anyone named on, any government prohibited, denied, unverified-party, sanctions, debarment, or exclusion list or export-controlled related restricted party list (collectively, "Sanctions Lists"). You will immediately discontinue your use of the Services if you, or a party exercising control over you, are placed on any Sanctions List.

Excerpt from Coursera's Terms of Use

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1. REGULATORY LANDSCAPE: Export control compliance engages US Office of Foreign Assets Control (OFAC) sanctions programs, Export Administration Regulations (EAR), and analogous sanctions regimes in the EU and UK. Educational services provided to sanctioned countries or nationals may have specific carve-outs under applicable US export control law, which the terms do not explicitly address. The prohibition on VPN circumvention aligns with US sanctions enforcement expectations. 2. GOVERNANCE EXPOSURE: Low for most users. Enterprise customers with international workforces should assess whether the sanctions warranty and immediate discontinuation obligation create operational gaps for employees in or traveling to sanctioned jurisdictions. 3. JURISDICTION FLAGS: Users in countries subject to US sanctions, including Cuba, Iran, North Korea, Syria, and Russia, are prohibited from accessing the services. Enterprise customers with operations or employees in these jurisdictions face operational implications regardless of corporate location. The terms note that location is determined by physical location, which may affect users who travel to sanctioned jurisdictions. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should assess whether organizational compliance with US sanctions regimes is adequately documented and whether the user warranty creates individual user-level compliance obligations that the organization must manage. Coursera retains the right to terminate service immediately upon identifying a sanctions compliance concern, which may affect organizational access to learning resources. 5. COMPLIANCE CONSIDERATIONS: Legal teams should establish processes for monitoring sanctions list updates and assessing whether any organizational users may trigger the immediate discontinuation obligation. The VPN prohibition should be communicated to employees who use VPN services for network security purposes, as the prohibition is limited to circumvention of geographic access restrictions.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Get same-day alerts when this changes → Get Analyst

Monitor: same-day alerts on the platforms you choose. Analyst: full institutional analysis.

Applicable agencies

  • FTC
    The FTC has general consumer protection authority over material access restriction disclosures in consumer-facing service agreements.
    File a complaint →

Provision details

Document information
Document
Coursera Terms of Use
Entity
Coursera
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014373
Document ID
CA-D-00157
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c2d2933e0991178d20d334605bd68ade792039ffde33bca392a477503180019f
Analysis generated
July 9, 2026 05:25 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coursera
Document: Coursera Terms of Use
Record ID: CA-P-014373
Captured: 2026-07-09 05:25:55 UTC
SHA-256: c2d2933e0991178d…
URL: https://conductatlas.com/platform/coursera/coursera-terms-of-use/provision/CA-P-014373/export-controls-and-sanctions-compliance-warranty/
Accessed: July 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

Compliance Governance Intelligence

Need to monitor specific governance provisions?

Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Get Compliance

Or start with Monitor →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

What does Coursera's Export Controls and Sanctions Compliance Warranty clause do?

This provision frames sanctions compliance as a user warranty that is confirmed upon each service use, and expressly prohibits VPN or IP routing circumvention of geographic restrictions. Coursera may terminate service immediately for sanctions compliance breaches or where continued service provision may cause commercial or reputational harm, at Coursera's sole discretion.

How does this clause affect you?

Under this clause, users in sanctioned countries or on government restricted party lists are prohibited from using the services, and use of VPN or IP routing services to circumvent geographic restrictions constitutes a terms violation. Users placed on a Sanctions List must immediately discontinue access, and Coursera may terminate service access unilaterally upon identifying a compliance risk.

Is ConductAtlas affiliated with Coursera?

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