Without U.S. Government approval, U.S. law prohibits "U.S. persons" from facilitating in any transaction involving, directly or indirectly, a country against which the U.S. has broad trade sanctions ("sanctioned country"). The following URL will access the U.S. State Department's Office of Foreign Assets Control Division web-site which contains information on the countries against which the U.S. has broad trade sanctions:
https://home.treasury.gov
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". "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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