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The agreement requires both parties to warrant compliance with applicable anti-corruption, anti-money laundering, sanctions, export controls, and anti-boycott laws, and requires customers to represent that their Affiliates and End Users are not on any sanctions or restricted party lists, with immediate discontinuation of service required if any party becomes listed.
This analysis describes what Twilio'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 extends restricted party list screening obligations to the customer's Affiliates and End Users, requiring customers to monitor and immediately discontinue access for any End User placed on a U.S. OFAC Specially Designated Nationals List or BIS Entity List, which creates ongoing compliance obligations at scale.
The updated terms establish a different dispute resolution process for customers domiciled or registered in Mexico. Previously, Mexico was subject to the standard arbitration venue clause routing disputes to San Francisco, California. Under the revised agreement, Mexican customers must first engage in good faith negotiations with Twilio's senior representatives for 30 days; if unresolved, disputes proceed to binding arbitration under Centro de Arbitraje de México (CAM) rules, conducted in English in Mexico City before a sole arbitrator. The agreement also explicitly states that Mexican consumer protection law (Ley Federal de Protección al Consumidor) does not apply to the commercial relationship between the parties. Mexico-domiciled customers should review the updated dispute resolution procedures and understand that consumer protection law carve-out before continuing use.
View change record →The updated terms establish two new regional service entities: CISA Telecomunicaciones for Mexico and Teravoz Telecom for Brazil, meaning customers in those jurisdictions will contract with the local entity rather than Twilio Inc. The agreement now permits orders to be placed through Twilio's online self-service purchasing workflow in addition to traditional written order forms, streamlining how purchase terms can be documented. The updated language also removes the prior commitment that Twilio will not materially decrease overall service functionality, replacing it with a general statement that services may change over time without specific protections on functionality levels.
View change record →The updated terms now route Twilio service agreements for Mexico and Brazil customers to new regional entities rather than Twilio Inc., which may affect service delivery, dispute resolution venue, and applicable local law. The definition of Order Form was expanded to explicitly include self-service online purchases, clarifying that terms negotiated through Twilio's account interface carry the same contractual weight as traditional executed agreements. The terms also removed language stating that Twilio would not materially decrease overall service functionality, replacing it with a simpler statement that services may change over time, which narrows the operational commitment Twilio makes regarding service stability. You can review the separate agreements that now govern your use based on your regional location.
View change record →Under these terms, customers warrant that their Affiliates and End Users are not on applicable sanctions or restricted party lists and are required to immediately discontinue End User access if any End User becomes listed, with account suspension authorized upon breach.
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"Each party (a) warrants that it will comply with all applicable anti-corruption, anti-money laundering, and international trade laws, including, without limitation, sanctions, export controls, import, and anti-boycott laws, regulations, and governmental orders (collectively, "Anti-Corruption and Trade Laws") in the jurisdictions that apply directly or indirectly to the Services, including, without limitation, the United States, and (b) represents that it has not made, offered, promised to make, or authorized any payment or anything of value in violation of Anti-Corruption and Trade Laws. ... Each party represents that it (and in your case, also your Affiliates and End Users) is not on any applicable sanctions or export controls restricted party list.Excerpt from Twilio's Terms of Service
(1) REGULATORY LANDSCAPE: The anti-corruption and international trade law warranties engage U.S. OFAC sanctions regulations, U.S. Export Administration Regulations administered by BIS, the Foreign Corrupt Practices Act, and applicable anti-money laundering law. Non-compliance may result in regulatory enforcement by OFAC or BIS independent of any contractual consequences. The EU has parallel sanctions frameworks that may apply to EU-based customers. (2) GOVERNANCE EXPOSURE: High. The requirement to screen and monitor End Users against restricted party lists creates ongoing operational obligations, particularly for customers with large or international End User bases. The obligation to immediately discontinue End User access upon listing creates a real-time monitoring requirement. (3) JURISDICTION FLAGS: U.S. sanctions regulations apply extraterritorially in many circumstances, creating compliance obligations for non-U.S. customers using Twilio services. EU customers are subject to parallel EU sanctions frameworks. The agreement references U.S. law specifically but notes that the warranties apply to all jurisdictions that apply directly or indirectly to the services. (4) CONTRACT AND VENDOR IMPLICATIONS: Customers should assess whether their existing sanctions screening and monitoring processes cover their Affiliates and End Users at the frequency and completeness required to satisfy the warranty asserted in this provision. Enterprise customers with large End User populations may need to implement automated screening tools. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should review their sanctions screening processes and confirm that screening covers all Affiliates and End Users accessing Twilio-powered services. Any identified restricted party should trigger immediate access termination and written notification to Twilio as required by the agreement. Legal teams should assess whether the anti-corruption warranty requires any updates to internal compliance programs or vendor due diligence procedures.
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This provision extends restricted party list screening obligations to the customer's Affiliates and End Users, requiring customers to monitor and immediately discontinue access for any End User placed on a U.S. OFAC Specially Designated Nationals List or BIS Entity List, which creates ongoing compliance obligations at scale.
Under these terms, customers warrant that their Affiliates and End Users are not on applicable sanctions or restricted party lists and are required to immediately discontinue End User access if any End User becomes listed, with account suspension authorized upon breach.
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