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The agreement requires both parties to comply with applicable anti-corruption, sanctions, export control, and anti-boycott laws, and requires customers to represent that they, their affiliates, and their End Users are not on any applicable restricted party list, with an obligation to immediately discontinue service use if placed on such a list.
This analysis describes what Segment'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 extends the restricted party list screening obligation to the customer's End Users and affiliates, not only the customer itself. The obligation to immediately discontinue service upon placement on a restricted party list could require rapid operational action without a grace period.
The updated terms establish a binding arbitration requirement for users domiciled or registered in Mexico, replacing prior dispute resolution procedures. Under the revised Section 10.5, Mexico-domiciled users must first engage in good faith negotiations with Segment for up to 30 days, and if unresolved, disputes proceed to binding arbitration administered by the Centro de Arbitraje de México (CAM) in Mexico City before a sole arbitrator, with both parties splitting arbitration costs. Additionally, the agreement now explicitly carves out Mexico's Federal Consumer Protection Law (Ley Federal de Protección al Consumidor), stating it does not apply to this commercial agreement. Mexico users also face a new obligation to comply with anti-money laundering and anti-corruption requirements under applicable Mexican law.
View change record →Segment's updated terms now apply Japan-specific dispute resolution, verification, and tax requirements to customers domiciled or registered in Japan. The agreement now states that arbitration proceedings for Japanese customers will take place in Mexico City, Japan (implied Tokyo venue under the new Japan section), conducted in English. Japanese customers may be required to submit government-issued ID documents and complete verification processes as required under applicable Japanese law, including the Act on Prevention of Transfer of Criminal Proceeds and the Telecommunications Business Act. All fees are payable in Japanese Yen, and taxes will include Japanese consumption tax. Intellectual property rights now incorporate Japanese Copyright Act provisions. You can review the specific verification requirements by contacting Segment or reviewing the applicable service section.
View change record →Under this clause, customers are required to screen not only themselves but also their affiliates and End Users against applicable restricted party lists, and must immediately remove End User access and discontinue their own service use if any placement on a restricted party list occurs.
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"Each party (a) warrants that it will comply with all applicable anti-corruption, anti-money laundering, and international trade laws, including, without limitation, sanctions, export controls, import, and anti-boycott laws, regulations, and governmental orders (collectively, "Anti-Corruption and Trade Laws") in the jurisdictions that apply directly or indirectly to the Services, including, without limitation, the United States, and (b) represents that it has not made, offered, promised to make, or authorized any payment or anything of value in violation of Anti-Corruption and Trade Laws. Each party represents that it (and in your case, also your Affiliates and End Users) is not on any applicable sanctions or export controls restricted party list, including, without limitation, the U.S. Office of Foreign Assets Controls, Specially Designated Nationals List, and the U.S. Bureau of Industry and Security Entity List. You will immediately (i) discontinue your use of the Services if you become placed on any Restricted Party List by designation or ownership and (ii) remove your End Users' access to the Services if your End Users become placed on any Restricted Party List by designation or ownership.Excerpt from Segment's Terms of Service
REGULATORY LANDSCAPE: This provision directly engages US OFAC sanctions regulations, the Export Administration Regulations administered by the US Bureau of Industry and Security, and the Foreign Corrupt Practices Act. Equivalent frameworks in the EU, UK, and other jurisdictions where the customer operates may also apply. Enforcement authorities include OFAC, BIS, and the US Department of Justice. GOVERNANCE EXPOSURE: Medium. For customers operating global platforms with large End User populations, screening all End Users against restricted party lists presents an operational compliance challenge. The immediate discontinuation requirement upon placement means that automated screening and monitoring processes must be in place to meet this obligation in real time. JURISDICTION FLAGS: Customers with operations or End Users in sanctioned jurisdictions, or in sectors subject to heightened export control scrutiny such as dual-use technology, face elevated exposure. EU and UK customers must also evaluate their own sanctions frameworks, which may differ in scope from US OFAC restrictions. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should assess whether existing vendor compliance programs include Twilio-specific screening obligations for End Users and affiliates. The immediate discontinuation requirement may require integration of real-time or frequent-batch restricted party list screening into customer onboarding and monitoring workflows. COMPLIANCE CONSIDERATIONS: Legal and compliance teams should implement a sanctions and export controls screening program that covers the customer's Twilio-connected End User population and affiliates, and should establish a documented process for responding to restricted party list placements within the immediate discontinuation timeframe required by the agreement.
This provision extends the restricted party list screening obligation to the customer's End Users and affiliates, not only the customer itself. The obligation to immediately discontinue service upon placement on a restricted party list could require rapid operational action without a grace period.
Under this clause, customers are required to screen not only themselves but also their affiliates and End Users against applicable restricted party lists, and must immediately remove End User access and discontinue their own service use if any placement on a restricted party list occurs.
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