Without U.S. Government approval, U.S. law prohibits U.S. persons from facilitating in any transaction involving, directly or indirectly, a sanctioned country. The use of software applications hosted on a U.S.-based server for any transaction involving, directly or indirectly, a sanctioned country may be considered facilitation. The countries currently sanctioned by the U.S. Government are: Cuba, Iran and Sudan. U.S. person is defined to include: (a) U.S. nationals, wherever located; (b) foreign nationals employed by any U.S. incorporated company (such as GE and GEII) wherever located; (c) other foreign nationals while present in the U.S. and holding a valid U.S. Green Card; and (d) [for the Cuba sanctions only] foreign nationals employed by any controlled subsidiary of a U.S. incorporated company (such as GE and GEII) wherever located. For businesses located in Canada, Mexico or any European Union nation, anti-blocking statutes apply with respect to the U.S. sanctions. Advice on complying with any relevant anti-blocking statutes should be obtained from legal counsel.
Accessing technical data hosted on a U.S.-based application or server from outside the U.S. is considered an export of that technical data. It is your obligation to comply with all relevant U.S. export laws.
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