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The agreement prohibits access by users who are on OFAC or other governmental sanctions lists, or who are citizens, residents, or entities organized in jurisdictions subject to comprehensive U.S. economic sanctions, and requires users to represent compliance with all applicable laws as a condition of access.
This analysis describes what Uniswap'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 user-level sanctions compliance representations as a contractual condition of access to all products. The provision relies on user self-attestation rather than specifying any technical or identity-based verification mechanism, which is an operationally relevant distinction for compliance assessment of whether the restriction is actively enforced.
The updated terms establish new contractual representations that users must make when agreeing to the agreement. Users now represent that they are not subject to economic or trade sanctions administered by any governmental authority, including OFAC lists, and that they are not citizens or residents of sanctioned jurisdictions. Users also represent that their access and use will comply with all applicable laws and will not be used to conduct or facilitate illegal activity. These representations are legally binding attestations that may be verified. Users in OFAC-sanctioned countries cannot truthfully make these representations and would be unable to use the platform.
View change record →The updated terms establish new restrictions on user conduct and add affirmative representations regarding asset eligibility. Users trading tokenized real-world assets (such as tokenized stocks, ETFs, or commodities) must now represent that they have reviewed issuer information and comply with any restrictions on trading or holding those assets. The terms also explicitly prohibit circumventing access restrictions, including geographic blocks and transfer limitations imposed by token issuers. By continuing to use the platform, users affirm they are legally eligible to trade tokens under their jurisdiction's laws.
View change record →The updated terms establish that Uniswap does not warrant that any digital asset accessible through its products is available for trading, holding, or transacting in your jurisdiction, or that you are legally permitted to do so. The revised language places the burden on you to determine whether a digital asset is lawfully available to you and to comply with any applicable transfer restrictions imposed by asset issuers or regulatory authorities. This means accessing or trading an asset through the Uniswap interface does not constitute Uniswap's determination that you are eligible to do so under your local laws.
View change record →Under this clause, users must represent at the point of access that they are not subject to OFAC designation, not on prohibited party lists, and not located in or organized under the laws of a comprehensively sanctioned jurisdiction. The agreement does not describe any technical access restriction or identity verification mechanism for enforcing this prohibition; enforcement of this provision relies on user representation.
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Customer may not indicate that a product or service developed with the Software is sponsored or endorsed by NVIDIA unless expressly authorized in writing by NVIDIA.
You may not...engage in any other conduct that restricts any person from using our Services, or that we reasonably believe exposes us...to any liability, damages, or harm, including reputational harm.
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"You further represent that you are not (a) the subject of economic or trade sanctions administered or enforced by any governmental authority or otherwise designated on any list of prohibited or restricted parties (including but not limited to the list maintained by the Office of Foreign Assets Control of the U.S. Department of the Treasury) or (b) a citizen, resident, or organized in a jurisdiction or territory that is the subject of comprehensive country-wide, territory-wide, or regional economic sanctions by the United States. Finally, you represent that your access and use of any of our Products will fully comply with all applicable laws and regulations, and that you will not access or use any of our Products to conduct, promote, or otherwise facilitate any illegal activity.Excerpt from Uniswap's Terms of Service
1) REGULATORY LANDSCAPE: OFAC sanctions compliance requirements apply to U.S. persons and entities, and to transactions involving U.S. jurisdiction, under the International Emergency Economic Powers Act and related statutes. OFAC has issued guidance specific to digital asset businesses, and failure to screen users against OFAC's Specially Designated Nationals list can result in civil and criminal penalties regardless of whether the company relied on user self-attestation. The Financial Crimes Enforcement Network (FinCEN) and state money transmitter licensing frameworks may impose independent user verification obligations depending on the regulatory classification of Uniswap Labs' products. 2) GOVERNANCE EXPOSURE: High. The reliance on user-representation-only sanctions compliance, without described technical screening or identity verification, may not satisfy OFAC compliance program standards applicable to financial service providers, particularly if Uniswap Labs' products are classified as money services or financial intermediaries. OFAC has previously penalized virtual asset service providers for sanctions violations where user self-attestation was the sole control. 3) JURISDICTION FLAGS: U.S. sanctions law applies extraterritorially in certain circumstances, creating exposure for non-U.S. users and for transactions that touch U.S. financial infrastructure. Jurisdictions with residents subject to comprehensive U.S. sanctions include Iran, North Korea, Cuba, Syria, and the Crimea, Donetsk, and Luhansk regions, among others, as designated by OFAC. 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party partners accessing Uniswap Labs APIs or integrating the interface into their platforms should assess their own independent OFAC compliance obligations and should not rely on Uniswap Labs' user representation mechanism as a substitute for their own screening programs. 5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should assess whether Uniswap Labs' products qualify as a virtual asset service provider or money services business under applicable definitions, which would trigger independent OFAC compliance program requirements including transaction screening, customer identification, and recordkeeping obligations beyond user self-attestation.
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This provision establishes user-level sanctions compliance representations as a contractual condition of access to all products. The provision relies on user self-attestation rather than specifying any technical or identity-based verification mechanism, which is an operationally relevant distinction for compliance assessment of whether the restriction is actively enforced.
Under this clause, users must represent at the point of access that they are not subject to OFAC designation, not on prohibited party lists, and not located in or organized under the laws of a comprehensively sanctioned jurisdiction. The agreement does not describe any technical access restriction or identity verification mechanism for enforcing this prohibition; enforcement of this provision relies …
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