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The purchaser agrees to comply with all applicable export control and sanctions laws including U.S. BIS Export Administration Regulations, OFAC sanctions regulations, EU export control and sanctions measures, and UK HM Treasury rules. The purchaser agrees not to export, re-export, or transfer purchased products to any person or entity subject to restrictions under these laws.
This analysis describes what Ledger'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 contractually obligates each purchaser to independently comply with a broad set of international export control and sanctions regimes as a condition of purchase. The document also includes specific contractual prohibitions on re-export of covered goods to Russia or Belarus referencing specific EU Council Regulations, reflecting recent regulatory changes.
Under this clause, the agreement requires each purchaser to confirm that they will not export, re-export, or transfer purchased products to any country, individual, or entity restricted under applicable U.S., EU, or UK export control and sanctions laws. The agreement also includes a specific prohibition on direct or indirect re-export to Russia or Belarus.
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"YOU AGREE TO COMPLY WITH APPLICABLE RULES PERTAINING TO EXPORT CONTROL AND SANCTIONS LAWS OF THE APPLICABLE GOVERNMENTAL AUTHORITY HAVING JURISDICTION (SUCH AS EMBARGOES IMPOSED ON SPECIFIC COUNTRIES, OR ECONOMIC SANCTIONS IMPOSED ON INDIVIDUALS OR COMPANIES FOR TERRORISM OR MONEY LAUNDERING OFFENCES), INCLUDING THE U.S. EXPORT ADMINISTRATION REGULATIONS ADMINISTERED BY THE U.S. DEPARTMENT OF COMMERCE'S BUREAU OF INDUSTRY AND SECURITY ("BIS"), THE U.S. SANCTIONS REGULATIONS ADMINISTERED BY THE U.S. TREASURY DEPARTMENT'S OFFICE OF FOREIGN ASSETS CONTROL ("OFAC"), THE EUROPEAN UNION, ANY EUROPEAN UNION MEMBER STATE OR HER MAJESTY'S TREASURY OF THE UNITED KINGDOM (COLLECTIVELY, "EXPORT CONTROL AND SANCTIONS LAWS"). THEREFORE, YOU AGREE NOT TO EXPORT, RE-EXPORT, OR TRANSFER ANY PRODUCTS (INCLUDING SOFTWARE) THAT YOU HAVE PURCHASED ON THE WEBSITE TO ANY COUNTRY, INDIVIDUAL, CORPORATION, ORGANISATION, OR ENTITY TO WHICH SUCH EXPORT IS RESTRICTED OR PROHIBITED UNDER THE EXPORT CONTROL AND SANCTIONS LAWS.Excerpt from Ledger's Terms of Sale
(1) REGULATORY LANDSCAPE: This provision directly engages U.S. Export Administration Regulations (15 CFR Parts 730-774), OFAC sanctions programs, EU Council Regulations 833/2014 and 765/2006 (as amended through 2024), and UK HM Treasury sanctions. Enforcement authorities include U.S. Department of Commerce BIS, U.S. Treasury OFAC, EU member state competent authorities, and UK Office of Financial Sanctions Implementation (OFSI). The Russia and Belarus re-export prohibition references specific EU Council Regulations including Article 12g of Regulation 833/2014 as amended by Regulation 2023/2878 and Article 8g of Regulation 765/2006 as amended by Regulation 2024/1865. (2) GOVERNANCE EXPOSURE: High. The contractual imposition of export control compliance obligations on individual consumer purchasers is significant, and violations of applicable export control and sanctions laws carry substantial civil and criminal penalties. The inclusion of specific EU regulatory citations for Russia and Belarus re-export prohibitions reflects current regulatory requirements that are enforceable against exporters regardless of contractual allocation. (3) JURISDICTION FLAGS: This provision applies to all purchasers globally. U.S. persons and entities are subject to BIS and OFAC jurisdiction regardless of where they are located. EU persons are subject to applicable EU restrictive measures. UK persons are subject to UK sanctions law. Heightened exposure exists for purchasers in or dealing with sanctioned jurisdictions, designated persons, or restricted end-uses. (4) CONTRACT AND VENDOR IMPLICATIONS: Institutional purchasers and resellers should note that this provision is in addition to their independent legal obligations under applicable export control law. The contractual prohibition on re-export to Russia or Belarus should be incorporated into institutional re-export and end-use screening procedures. (5) COMPLIANCE CONSIDERATIONS: Institutional compliance programs should verify that internal export control and sanctions screening procedures cover Ledger hardware wallet products, including classification under applicable export control schedules. The Russia and Belarus re-export prohibition should be reflected in internal supply chain and customer due diligence policies.
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Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision contractually obligates each purchaser to independently comply with a broad set of international export control and sanctions regimes as a condition of purchase. The document also includes specific contractual prohibitions on re-export of covered goods to Russia or Belarus referencing specific EU Council Regulations, reflecting recent regulatory changes.
Under this clause, the agreement requires each purchaser to confirm that they will not export, re-export, or transfer purchased products to any country, individual, or entity restricted under applicable U.S., EU, or UK export control and sanctions laws. The agreement also includes a specific prohibition on direct or indirect re-export to Russia or Belarus.
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