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The agreement requires users to comply with prohibitions imposed by relevant sanctions authorities and prohibits use of the End User Services in violation of applicable sanctions regimes.
This analysis describes what Stripe'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 establishes that users are contractually obligated to comply with applicable sanctions requirements, which may include obligations imposed by U.S. OFAC, EU sanctions authorities, UK OFSI, and other relevant bodies depending on the user's jurisdiction and the nature of transactions conducted.
Interpretive note: The phrase 'relevant sanctions authorities' is not defined in the document, and the scope of applicable sanctions regimes depends on the user's jurisdiction, counterparties, and transaction type.
Under this clause, users operating in or transacting with sanctioned jurisdictions or parties may be in breach of the agreement regardless of whether they are directly subject to the relevant sanctions authority's jurisdiction. The phrase 'relevant sanctions authorities' is not defined and may encompass multiple international regimes.
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Customer must comply with any additional terms, restrictions, or limitations (e.g., limitations on the total amount of usage) for a promotional offering as described in the corresponding offer terms.
You agree to comply with all applicable local, state, federal and/or international laws or regulations, including those related to AI systems, privacy, and data protection.
Please take steps to secure your access credentials such as login name and password, and do not share them with anyone.
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"You must not, and must not allow others to: Use the End User Services in a way that violates prohibitions relevant sanctions authorities impose.Excerpt from Stripe's Acceptable Use Policy
1. REGULATORY LANDSCAPE: This provision directly engages U.S. OFAC sanctions programs, EU Common Foreign and Security Policy sanctions, UK OFSI sanctions, and potentially UN Security Council sanctions regimes. The phrase 'relevant sanctions authorities' is deliberately broad and may encompass multiple overlapping regimes. Non-compliance with OFAC requirements can result in civil and criminal penalties under the International Emergency Economic Powers Act and the Trading With the Enemy Act. 2. GOVERNANCE EXPOSURE: High. The provision places affirmative compliance obligations on users without specifying which sanctions regimes apply or what due diligence is required. Organizations with international operations or cross-border transactions face heightened exposure given the multiplicity of potentially applicable sanctions regimes. 3. JURISDICTION FLAGS: EU users are subject to EU Council regulations implementing sanctions, which may differ from U.S. OFAC programs in scope and covered parties. UK users are subject to OFSI-administered sanctions following Brexit. Users in jurisdictions with limited access to sanctions compliance resources may face practical difficulties meeting the compliance standard implied by this clause. 4. CONTRACT AND VENDOR IMPLICATIONS: For B2B relationships, this clause may require downstream contract amendments to ensure that partners and vendors using Stripe's End User Services in connection with shared workflows are similarly restricted. Procurement teams should assess whether existing vendor agreements adequately address sanctions compliance obligations. 5. COMPLIANCE CONSIDERATIONS: Legal and compliance teams should conduct a sanctions screening review of all counterparties and jurisdictions involved in activities conducted through the End User Services. Where operations span multiple jurisdictions, a multi-regime sanctions compliance program may be required to satisfy the 'relevant sanctions authorities' standard.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes that users are contractually obligated to comply with applicable sanctions requirements, which may include obligations imposed by U.S. OFAC, EU sanctions authorities, UK OFSI, and other relevant bodies depending on the user's jurisdiction and the nature of transactions conducted.
Under this clause, users operating in or transacting with sanctioned jurisdictions or parties may be in breach of the agreement regardless of whether they are directly subject to the relevant sanctions authority's jurisdiction. The phrase 'relevant sanctions authorities' is not defined and may encompass multiple international regimes.
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
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