Sections 16.11 and 16.12 assign sole responsibility to Customer for export control and trade sanctions compliance, prohibit use in U.S. embargoed countries or by restricted parties, and restrict Service access to supported countries and territories, with violations subject to Service suspension.
This analysis describes what OpenAI'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
These provisions assign compliance responsibility for trade controls entirely to Customer and restrict geographic access to Services, creating operational obligations for customers with international operations or End Users in or near sanctioned jurisdictions.
The agreement makes Customer solely responsible for compliance with U.S. and applicable trade laws, sanctions, and export controls, and prohibits Service access outside of OpenAI's supported countries and territories. Violations of geographic restrictions may result in Service suspension.
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Compare across platforms →"Customer is solely responsible for ensuring that its use of the Services complies with applicable trade laws, including sanctions and export control laws. Customer's Input may not include material or information that requires a government license for release or export. Customer may not use the Services in or for the benefit of, or export or re-export the Services to, any U.S. embargoed countries or to anyone on a Restricted Party List. ... Customer and End Users may not access or offer access to the Services outside of the Supported Countries and Territories. A violation of this Section 16.12 may result in Services suspension under Section 8.Excerpt from OpenAI's Business Terms
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These provisions assign compliance responsibility for trade controls entirely to Customer and restrict geographic access to Services, creating operational obligations for customers with international operations or End Users in or near sanctioned jurisdictions.
The agreement makes Customer solely responsible for compliance with U.S. and applicable trade laws, sanctions, and export controls, and prohibits Service access outside of OpenAI's supported countries and territories. Violations of geographic restrictions may result in Service suspension.
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