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Software (Duo and Zoom) bans in Sanctioned Countries

Overview of Issue:  As of May 2022, software and app providers (i.e., Duo and Zoom) are banning their services in heavily OFAC sanctioned countries. Northwestern faculty, staff, and students based in or traveling to these countries or regions will not be able to access or communicate via most University-provided technology resources. We assess the most significant impact is on international students who may need to use Duo or ZOOM before arriving to the U.S. and faculty who travel to sanctioned countries.  

Export Language in Duo User Agreement:  In connection with its use of the Services, Customer agrees to comply with the laws or regulations of the United States Department of Commerce, the United States Department of Treasury Office of Foreign Assets Control, or any other applicable United States or foreign agency or authority. Each party represents that it is not named on any U.S. government denied-party list. Customer agrees to not access or use, agrees to instruct its Users not to access or use, the Services in a U.S. embargoed country without U.S. Government authorization. 

DUO states that OFAC restrictions relevant to Duo currently apply to the following countries or regions: 

  • Cuba 
  • North Korea
  • Iran 
  • Sudan 
  • Syria 
  • Crimea region of Ukraine
  • Donetsk region of Ukraine
  • Luhansk region of Ukraine
  • Sevastopol region of Ukraine

Other software and encryption services are also banned and may be an export violation to use or provide these services.