The agreement requires customers to comply with U.S. export controls and OFAC regulations, and states that upon termination for export control breach, the customer loses all rights to Customer Content, which Figma may immediately quarantine, delete, or remove. Figma may suspend access or terminate the agreement to comply with applicable legal obligations.
This analysis describes what Figma'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
This provision establishes that a termination for export control breach results in forfeiture of all rights to Customer Content held by Figma, with immediate deletion or quarantine authorized. This is a materially distinct consequence compared to standard termination provisions, which include a 30-day post-termination retrieval period for Customer Content. The loss of Customer Content upon export control termination creates significant data loss risk for affected customers.
Under this clause, if the agreement is terminated due to an export control violation, the customer forfeits all rights to Customer Content and Figma may immediately delete or quarantine that content without the 30-day retrieval period available under standard termination. Figma may also suspend access immediately based on its own compliance obligations under OFAC.
Cross-platform context
See how other platforms handle Export Control Compliance and Content Forfeiture and similar clauses.
Compare across platforms →"Customer must comply with all applicable Export Controls in Customer's access to and use of the Figma Platform and Customer Content. Customer will not access or use the Figma Platform, export, re-export, distribute, assign, or otherwise engage in any transaction relating to the Figma Platform or any Customer Content in violation of Export Controls. For the avoidance of doubt, Figma may take measures required by law or governmental authority to comply with its obligations under Export Controls and OFAC (such as suspending access to the Figma Platform, terminating this Agreement, or blocking the relevant Customer Content). [...] Notwithstanding the foregoing, upon termination of this Agreement for breach of Section 9.12 (Export Control), you lose all right, title, and interest to Customer Content, and Figma may immediately quarantine, delete, or remove Customer Content, and immediately suspend your use of and access to the Figma Platform.Excerpt from Figma's Terms of Service (Superseded URL)
(1) REGULATORY LANDSCAPE: This provision directly references U.S.
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This provision establishes that a termination for export control breach results in forfeiture of all rights to Customer Content held by Figma, with immediate deletion or quarantine authorized. This is a materially distinct consequence compared to standard termination provisions, which include a 30-day post-termination retrieval period for Customer Content. The loss of Customer Content upon export control termination creates significant …
Under this clause, if the agreement is terminated due to an export control violation, the customer forfeits all rights to Customer Content and Figma may immediately delete or quarantine that content without the 30-day retrieval period available under standard termination. Figma may also suspend access immediately based on its own compliance obligations under OFAC.
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