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The terms prohibit use of the Platform in connection with transactions, services, or activities involving embargoed jurisdictions including Cuba, Iran, North Korea, and specified Ukrainian regions, or persons on designated sanctions lists including the OFAC SDN List, UN Security Council Consolidated Sanctions List, and EU Consolidated Financial Sanctions List. Users must certify they are not located in or subject to these restrictions.
This analysis describes what TikTok'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 incorporates multi-jurisdictional export control and sanctions compliance obligations into the Terms, covering U.S., UK, EU, and Singapore regulatory frameworks, and extends user liability under the indemnification clause in Section 7 to violations of these requirements across all applicable jurisdictions.
⚠ Accounts of users found to be located in embargoed jurisdictions or designated on sanctioned party lists may be suspended without prior notice per Section 5.2.
⚠ Violations of export control or sanctions laws trigger the user indemnification obligation under Section 7, including attorneys' fees and settlement costs.
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"you must not use, or help anyone else use, the Platform to: sell, transfer, export, reexport, finance, order, buy, remove, conceal, store, use, loan, dispose of, transport, forward, or otherwise service, in whole or in part, any technology, software, commodity, or other item: to any country or territory for which the United States, United Kingdom, European Union, Singapore or any other applicable jurisdiction requires an export license... to anyone on any list of sanctioned parties issued and maintained by any relevant government authority or regulatory body, including but not limited to the United Nations Security Council Consolidated Sanctions List, the EU Consolidated Financial Sanctions List, any restricted party list published by the U.S. Treasury Department's Office of Foreign Assets Control, such as the Specially Designated Nationals and Blocked Persons List ("SDN List")... You also certify that you are not: located in, organized under the laws of, or ordinarily resident in an Embargoed Country, designated on any Sanctioned Party Lists.Excerpt from TikTok's Terms of Service
(1) REGULATORY LANDSCAPE: This provision engages OFAC regulations and U.S. Export Administration Regulations administered by the Commerce Department's Bureau of Industry and Security, as well as UK, EU, and Singapore sanctions and export control frameworks. Civil and criminal penalties for sanctions violations under these frameworks are significant and are not limited by the contractual liability cap in Section 4. (2) GOVERNANCE EXPOSURE: Medium. The provision places affirmative certification obligations on all users, including ordinary consumers, which is operationally unusual for a consumer social media platform. The inclusion of partial ownership and control thresholds for sanctioned parties creates compliance complexity for corporate users. (3) JURISDICTION FLAGS: The multi-jurisdictional scope of the sanctions compliance obligation means users in or connected to any of the named or implied embargoed jurisdictions face account suspension regardless of their intent. The occupied Ukrainian regions provision is particularly notable given the evolving conflict geography. Corporate users with operations in multiple jurisdictions should assess whether any affiliated entities fall within the 50 percent ownership or control threshold for sanctioned parties. (4) CONTRACT AND VENDOR IMPLICATIONS: Businesses using TikTok Platform services as part of commercial operations should include TikTok sanctions compliance terms in their vendor risk assessments and confirm that their own sanctions screening programs cover the full scope of lists referenced in this provision. The indemnification clause in Section 7 explicitly covers sanctions and export control violations, creating user-side financial exposure for non-compliance. (5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should ensure that user-facing onboarding and training programs address the Platform's sanctions compliance certification requirements. Organizations with international operations or connections to potentially sanctioned parties should conduct screening against the referenced lists before authorizing Platform use. The geographic scope of the Ukraine-related embargoed regions should be monitored given the potential for further territorial changes.
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This provision incorporates multi-jurisdictional export control and sanctions compliance obligations into the Terms, covering U.S., UK, EU, and Singapore regulatory frameworks, and extends user liability under the indemnification clause in Section 7 to violations of these requirements across all applicable jurisdictions.
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