“Customer must comply with all applicable Export Controls in Customer's access to and use of the Figma Platform and Customer Content.”
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
Non-compliance with export controls can carry significant legal consequences, and this clause places the compliance obligation squarely on the Customer.
The removal of the Subprocessors list link makes it less convenient for users, particularly enterprise and EU-based customers who rely on this information for data protection compliance, to verify which third parties Figma engages to process their data. While the subprocessor information may still exist on Figma's website, removing the direct link from the Terms of Service reduces accessibility and transparency. Enterprise customers and those subject to GDPR may need to contact Figma directly to access current subprocessor information.
View change record →Customers bear the obligation to ensure their access and use of the Figma Platform and Customer Content conforms to all applicable Export Controls.
How other platforms handle this
You must comply with all applicable trade laws, including sanctions and export control laws. Our Services may not be used in or for the benefit of, or exported or re-exported to (a) any U.S. embargoed country or territory...
Customer warrants it shall comply with all U.S. export control and economic sanctions laws and regulations as they relate to access to and use of the Application Services.
Customer is responsible for and hereby agrees to comply at its sole expense with all applicable United States export laws and regulations.
"Customer must comply with all applicable Export Controls in Customer's access to and use of the Figma Platform and Customer Content.Excerpt from Figma's Terms of Service
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Non-compliance with export controls can carry significant legal consequences, and this clause places the compliance obligation squarely on the Customer.
Customers bear the obligation to ensure their access and use of the Figma Platform and Customer Content conforms to all applicable Export Controls.
ConductAtlas has identified this type of provision across 182 platforms. See the full comparison.
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