Russia and Ukraine Export Compliance Updates
IMPORTANT: PLEASE READ THIS NOTICE CAREFULLY
The U.S. has announced new sanctions in response to Russia’s invasion of Ukraine.
These sanctions are now applicable to the direct or indirect sale, shipment or transfer of Ubiquiti products in Ukraine and Russia.
ADDITIONAL RESTRICTIONS ON PRODUCT DESTINATION
As a reminder, the direct or indirect sale, shipment or other transfer of any Ubiquiti products to any country or territory subject to U.S. embargoes or anti-terrorism controls is prohibited. Under a new Executive Order, Ubiquiti products can no longer be sold, shipped, or otherwise transferred into (1) the Donetsk region, or (2) the Luhansk region. Please see here for more information. Existing U.S. sanctions continue to prohibit the sale, shipment or transfer of Ubiquiti products into Crimea.
Accordingly, on global basis, the direct or indirect sale, shipment or other transfer of any Ubiquiti products to the following countries or territories is prohibited:
- North Korea
ADDITIONAL RESTRICTIONS ON CERTAIN ENTITIES AND INDIVIDUALS
The U.S. Treasury Department has added additional entities and individuals to its list of Specially Designed Nations (the "SDN List") in response to Russia’s invasion of Ukraine. These additions to the SDN List can be found here, but it is important to note that this list is regularly updated and amended and it is our responsibility as an official distributor of Ubiquiti and you as our reseller partner, to monitor the list to assure compliance with any and all updates thereto.
These additions to the SDN List are part of the broader set of prohibitions on the direct or indirect sale, shipment or other transfer of any Ubiquiti product to any entity or individual with whom transactions are prohibited under applicable export control and sanctions laws, including those listed on any applicable sanctioned party lists. These entities and individuals are included, without limitation, on the following lists, as amended from time to time:
RESTRICTIONS ON CERTAIN END-USES
The direct or indirect sale, shipment or other transfer of Ubiquiti products to government end-users, including Russian state-owned enterprises, or for a military end use/ to a military end-user in Russia, continues to be prohibited. Please see here for more information.
Ubiquiti products may not be used for or in connection with any nuclear, missile, chemical and biological weapons end uses.
Many of Ubiquiti’s products are classified as "ENC-Restricted" and cannot be transferred without a licence to government end-users other than those listed in Supplement No. 3 to Part 740 of the EAR. Generally, this prohibits the sale of all ENC-Restricted Ubiquiti products to government end-users outside of the United States, Canada, Europe, Japan, and Australia. Information on the Export Control Classification Number ("ECCN") of Ubiquiti’s products can be found here. With the exception of products classified with an ECCN of "EAR99" or "5A992" in the far-right column, any product with "5A002" should be treated as "ENC-Restricted" and therefore prohibited for direct or indirect sale to a government end-user.
Under the Export Administration Regulations, a government end-user is currently defined as "any foreign central, regional or local government department, agency, or other entity performing governmental functions; including governmental research institutions, governmental corporations or business units, and international governmental organizations." However, the term does not include: utilities (including telecommunications companies and Internet service providers); banks and financial institutions; transportation; broadcast or entertainment; educational organizations; civil health and medical organizations; retail or wholesale firms; and manufacturing or industrial entities.
SCOPE OF RESTRICTIONS
Each of these prohibitions apply to the direct or indirect sale, shipment or other transfer of any Ubiquiti products (1) directly by Ubiquiti, (2) by us as a distributor, and (3) by you as a direct or indirect reseller of Ubiquiti.
Failure to comply with U.S. export control and trade and economic sanctions laws and regulations can result in criminal sanctions, civil fines, debarment from government contracting, the loss of U.S. export privileges, and imprisonment. The reach of these laws and regulations covers U.S. persons as well as foreign persons, wherever located.
We as a distributor have a responsibility to make you aware of these sanctions and regulations and are expectant of your cooperation.
By directly or indirectly selling, shipping, using or otherwise transferring Ubiquiti’s products, you are agreeing to comply with all applicable export and reexport control laws and regulations, including each of those referenced herein.
GET IN TOUCH
Our dedicated team are here to provide the very best pre and post sales experience possible. If you have any requirements that you would like to discuss further please call us, email us or use our contact form and one of our team will get back to you as soon as possible.