By using Spotify, you confirm that you are not located in a sanctioned country and are not on any government restricted party list maintained by the EU, UK, or US. Spotify may refuse service or terminate accounts that violate these requirements.
This analysis describes what Spotify'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
The clause establishes a compliance representation that obligates users to certify their eligibility to use the service under applicable export control and sanctions regulations, requiring Spotify to verify user status against government-maintained restricted party lists.
Users are required to represent and warrant compliance with EU, UK, and US sanctions and export control lists as a condition of using the service. Users in sanctioned countries or on restricted party lists are prohibited from using Spotify under these terms.
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"You represent and warrant that you are (1) not located in, organized under the laws of, or ordinarily resident in any country or territory subject to territorial sanctions (collectively 'Sanctioned Country'), nor are you owned or acting on behalf of a government subject to asset-blocking sanctions or any person or entity organized, located or ordinarily resident in a Sanctioned Country; and (2) not a person identified on, or more than 50% owned or controlled, directly or indirectly, by or acting on behalf or at the direction of any entity identified on, E.U., U.K., or U.S., or other applicable government restricted party lists, such as the consolidated list of persons, groups and entities subject to EU financial sanctions, or the UK Consolidated List, or Specifically Designated Nationals list maintained by the US government.— Excerpt from Spotify's Spotify Terms and Conditions
REGULATORY LANDSCAPE: This provision engages EU Dual-Use Regulation (Regulation 2021/821 as amended), the UK Export Control Act 2002, the UK Export Control Order 2008, the US Export Administration Regulations, OFAC trade and economic sanctions, and the International Traffic in Arms Regulations. The relevant enforcement authorities include the US Department of Commerce Bureau of Industry and Security, the US Treasury Department Office of Foreign Assets Control, and equivalent EU and UK trade control authorities. User self-certification of sanctions status is a standard compliance mechanism but does not substitute for Spotify's independent obligations under applicable trade control law. GOVERNANCE EXPOSURE: Low for general consumer users in non-sanctioned jurisdictions. Medium to High for enterprise or developer users operating in geographically complex environments or with international user bases, where sanctions screening and compliance obligations are more operationally significant. JURISDICTION FLAGS: Users or organizations with operations in or connections to jurisdictions subject to US, EU, or UK sanctions face heightened compliance obligations and service access restrictions under this provision. Organizations with international user bases should assess whether their use of Spotify-integrated services creates downstream sanctions compliance obligations. CONTRACT AND VENDOR IMPLICATIONS: Organizations integrating Spotify APIs or services into their products should assess whether the export controls provision creates additional compliance obligations for their own sanctions screening processes. The provision expressly names EU, UK, and US trade control law frameworks, which may be relevant to organizations operating under multi-jurisdictional compliance programs. COMPLIANCE CONSIDERATIONS: Legal and compliance teams should confirm that organizational use of Spotify does not implicate applicable sanctions or export control restrictions, particularly if the service is deployed in jurisdictions with complex sanctions profiles. Trade compliance reviews should include Spotify in the scope of vendor and platform assessments where applicable.
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The clause establishes a compliance representation that obligates users to certify their eligibility to use the service under applicable export control and sanctions regulations, requiring Spotify to verify user status against government-maintained restricted party lists.
Users are required to represent and warrant compliance with EU, UK, and US sanctions and export control lists as a condition of using the service. Users in sanctioned countries or on restricted party lists are prohibited from using Spotify under these terms.
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