Sophos Crimea Guidance Note

Sophos is required to adhere to the laws and regulations of the United States, European Union and every country in which it conducts business. Non-compliance with Global Trade regulations can subject Sophos, and its Business Partners to criminal and civil penalties, the seizure of assets, and the denial of import or export privileges.

As a Business Partner, it is also expected to abide by relevant laws and regulations, inclusive of all business transactions with Sophos. As such, Sophos requires that your company becomes familiar with, and ensure compliance with U.S. and EU export regulations, and applicable export/import regulations in the countries which it operates.

On occasion we will send communications to highlight important regulatory information to reinforce business partner education on certain topics. Today we’d like to remind you of the regulatory changes in regards to exports to Crimea.

In response to the annexation of the Crimea region of the Ukraine, please be aware that the recent restrictions on transactions with the Crimea region imposed by the United States and European Union require Sophos business partners to cease transactions and communications with business partners and/or customers in the Crimea region.

THE FOLLOWING ACTIVITIES ARE EXPRESSLY PROHIBITED UNDER THE U.S. SANCTIONS:

1. New investment in the Crimea region of Ukraine;
2. The importation, directly or indirectly, of any goods, services, or technology from the Crimea region of Ukraine;
3. The exportation, reexportation, sale, or supply, directly or indirectly, of any goods, services, or technology to the Crimea region of Ukraine; and
4. Any approval, financing, facilitation, or guarantee of a transaction.

The scope of the restrictions includes the prohibition of any service or support for existing equipment in the Crimean region. Additionally, certain parties in Crimea have been added to the U.S. list of Specially Designated Nationals.

U.S. license applications for exports, reexports or transfers of U.S. EAR-regulated items will be subject to a presumption of denial, unless the item is included in the Office of Foreign Asset Control’s (OFAC) General License No. 4, which covers medical supplies and related replacement parts. BIS also amended the U.S. EAR to restrict the availability of License Exceptions for exports and reexports to the Crimea region. U.S. license exception “ENC”, which is used for many Sophos products, may no longer be used for exports to Crimea.

Although the E.U. has not imposed a comprehensive embargo on Crimea and Sevastopol, trade and investment is severely curtailed, details on regulatory compliance are found here: EU sanctions.

Additional information on the sanctions may be found here:

U.S. http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx

E.U. http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:JOL_2015_040_R_0003