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The policy prohibits any use of Stripe's services involving persons or entities listed on OFAC sanctions lists, the US Department of Commerce Denied Persons List or Entity List, or equivalent UK, EU, and UN restricted party lists.
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 contractually incorporates multi-jurisdictional sanctions screening obligations into Stripe's terms of service, requiring merchants to ensure that their customers and counterparties are not named on any of the specified restricted party lists.
Under this clause, merchants using Stripe are prohibited from processing any transactions that directly or indirectly involve persons or entities on OFAC, Commerce Department, UK, EU, or UN restricted party lists, regardless of the nature of the goods or services involved.
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"Persons Stripe has determined for various reasons, including legal, contractual, and commercial reasons, to be prohibited, such as those individuals or entities named to a restricted person or party list of, or otherwise restricted by, the United States, United Kingdom, European Union, or United Nations, including the sanctions maintained by the US Office of Foreign Assets Control or the Denied Persons List or Entity List maintained by the US Department of Commerce.Excerpt from Stripe's Restricted Businesses List
(1) REGULATORY LANDSCAPE: This provision directly implicates OFAC regulations under the International Emergency Economic Powers Act and the Trading with the Enemy Act, the US Department of Commerce Export Administration Regulations, and equivalent UK and EU sanctions frameworks. OFAC, the Bureau of Industry and Security, OFSI, and EU member state authorities are the relevant enforcement bodies. Violations of underlying sanctions law carry civil and criminal penalties independent of Stripe's contractual terms. (2) GOVERNANCE EXPOSURE: High. Merchants with international customer bases must implement restricted party screening procedures to comply with this provision. The inclusion of the UN list, UK list, and EU list alongside US lists creates a multi-jurisdictional screening obligation. (3) JURISDICTION FLAGS: All Stripe merchants globally are subject to this provision. Merchants in the EU and UK face additional exposure given the broader scope of those jurisdictions' sanctions regimes. Merchants in financial services, technology, and professional services sectors face heightened exposure given the Russia-specific service prohibitions that interact with this clause. (4) CONTRACT AND VENDOR IMPLICATIONS: B2B onboarding procedures should include restricted party screening against all four list categories named in this clause. Vendor assessment processes for businesses using Stripe as a payment processor should document screening procedures and outcomes. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain and regularly update screening procedures against OFAC SDN list, Commerce Denied Persons and Entity Lists, UK OFSI consolidated list, and relevant EU restricted party lists. Transaction monitoring should flag any matches for manual review prior to payment processing.
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This provision contractually incorporates multi-jurisdictional sanctions screening obligations into Stripe's terms of service, requiring merchants to ensure that their customers and counterparties are not named on any of the specified restricted party lists.
Under this clause, merchants using Stripe are prohibited from processing any transactions that directly or indirectly involve persons or entities on OFAC, Commerce Department, UK, EU, or UN restricted party lists, regardless of the nature of the goods or services involved.
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