Trade Compliance Policy

We serve organizations worldwide, except where sanctions or export control law forbids it. We follow the official lists as they change: a country, organization or person removed from a list is one we can work with again, and one added is one we stop working with.

This applies to every company in the Expandware group, to every service we provide and to every client, supplier and partner we work with.

• United Nations. Measures adopted by the United Nations Security Council, which bind every member state.
• United States. Sanctions administered by the Office of Foreign Assets Control, and export controls under the Export Administration Regulations administered by the Bureau of Industry and Security.
• European Union. Restrictive measures adopted by the Council of the European Union, where we work for clients in the EU or with EU goods and services.
• United Kingdom. Sanctions and export controls under United Kingdom law, where we work for clients in the United Kingdom.
• Local law. The law of Pakistan, where the delivery company is incorporated, and of any other country where a particular engagement is performed.

• People and organizations named on a sanctions list that applies to us, such as the United Nations Security Council Consolidated List or the OFAC Specially Designated Nationals list, and organizations owned or controlled by them under the rules that apply to ownership and control.
• Anyone located in, or acting for the government of, a country or region subject to a comprehensive embargo. At the date of this policy that includes Cuba, Iran, North Korea, and the Crimea, Donetsk and Luhansk regions of Ukraine.
• Persons in Russia, for the information technology consultancy, design, support and cloud services that United States, European Union and United Kingdom measures prohibit providing to them.
• Any end use the law prohibits, including the development of weapons of mass destruction or their delivery systems, and prohibited military end uses.

The contact form on this site does not accept enquiries from the embargoed locations listed above. That is a first filter, not a decision: whether we can work with a named organization is decided by screening it before we contract.

Some of the infrastructure we design and build is itself controlled. The most advanced AI accelerators, and the servers that contain them, are subject to United States export controls that require a licence for many destinations and end users, and some networking, security and encryption items are controlled too.

Before any controlled item is sourced, shipped or moved for an engagement, its classification and the licensing position for the destination and the end user are confirmed. We do not supply, transfer or install controlled items, or provide controlled technology, without the authorization the law requires, and we will decline or pause work until it is in place.

• New clients, suppliers and partners are screened against the consolidated lists before we contract with them.
• Existing relationships are screened again when the lists change materially, and at least once a year.
• A potential match is reviewed before any work continues, and escalated to legal advice where it is not clearly resolved.

The lists we screen against are public. The United States Consolidated Screening List at trade.gov combines the OFAC and Bureau of Industry and Security lists, and the United Nations, European Union and United Kingdom publish their own.

• Do not use our services, deliverables or any technology we provide in a way that breaches sanctions or export control law.
• Tell us promptly if you, or an organization that owns or controls you, becomes subject to sanctions.
• Tell us the end user and end use of any hardware we specify, source or install, where the law makes that relevant.

Where continuing would breach the law, we will suspend or end the work, as our agreements provide.

Questions about this policy, or a concern that something we are involved in may breach it, go to legal@expandware.com. Reports are handled confidentially and are not held against the person who raised them.