The policy prohibits use of End User Services in any manner that violates prohibitions imposed by relevant sanctions authorities, encompassing both the user's own conduct and use they permit by others.
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 requires users to independently comply with sanctions programs administered by relevant authorities, including OFAC in the United States, and equivalent bodies in other jurisdictions, as a condition of using End User Services.
Interpretive note: The phrase 'relevant sanctions authorities' is not defined in the document, creating potential ambiguity about which jurisdictions' sanctions programs the clause encompasses, particularly for users outside the United States.
Under this clause, users are required to ensure their use of End User Services does not violate any applicable sanctions regime, which may include restrictions on transactions involving sanctioned countries, entities, or individuals. The agreement places this compliance obligation directly on the user.
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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 Stripe Acceptable Use Policy
(1) REGULATORY LANDSCAPE: This provision directly engages U.S. OFAC sanctions programs, EU and UK sanctions regulations, and equivalent frameworks administered by relevant national authorities in Stripe's operating jurisdictions. OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. Violations of OFAC prohibitions can result in civil and criminal penalties. (2) GOVERNANCE EXPOSURE: High. Placing an affirmative sanctions compliance obligation on end users creates a contractual condition that mirrors regulatory requirements. Users in or with nexus to sanctioned jurisdictions, or who facilitate transactions involving sanctioned parties, may be in breach of both this policy and applicable law simultaneously. (3) JURISDICTION FLAGS: Users in the EU and UK are subject to parallel sanctions regimes administered by the European External Action Service and the UK Office of Financial Sanctions Implementation (OFSI) respectively. Organizations with global user bases should assess which sanctions frameworks apply to their user populations. Users in jurisdictions subject to comprehensive U.S. sanctions programs face the highest exposure under this clause. (4) CONTRACT AND VENDOR IMPLICATIONS: Businesses integrating Stripe End User Services into customer-facing workflows should assess whether their user base includes individuals or entities in sanctioned jurisdictions. The policy's prohibition on allowing others to violate sanctions extends liability considerations to platform operators who facilitate end user access. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether existing sanctions screening procedures cover the use of Stripe End User Services by employees, contractors, and customers. Organizations operating internationally should review whether any user populations create exposure under this clause and consider whether additional user eligibility controls are warranted.
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This provision requires users to independently comply with sanctions programs administered by relevant authorities, including OFAC in the United States, and equivalent bodies in other jurisdictions, as a condition of using End User Services.
Under this clause, users are required to ensure their use of End User Services does not violate any applicable sanctions regime, which may include restrictions on transactions involving sanctioned countries, entities, or individuals. The agreement places this compliance obligation directly on the user.
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