Export Control & Sanctions

Sanctioned Countries & Export Control Policy

HostupCloud operates under the laws and regulations of India, the United Kingdom, and the United States. As a result, we are subject to export control laws and economic sanctions programmes administered by multiple authorities including the US Office of Foreign Assets Control (OFAC), the UK Office of Financial Sanctions Implementation (OFSI), the European Union, and the United Nations Security Council (UNSC). This policy explains how these regulations affect who we can provide services to.

Last updated: 22 February 2026 · Effective: 22 February 2026 · Compliance contact: legal@hostupcloud.com

Overview India's Position Sanctioned Countries Restricted Persons Prohibited Uses Customer Obligations Compliance

1. Overview & Legal Basis

HostupCloud's Legal Entities & Applicable Law

🇬🇧 AL-GHANI NURNET LTD (UK)

Subject to UK OFSI sanctions, UK Export Control Order 2008, and UK implementation of UN Security Council resolutions.

🇺🇸 HOSTUPCLOUD, INC. (USA)

Subject to US OFAC sanctions, Export Administration Regulations (EAR / BIS), and ITAR where applicable.

🇮🇳 India Operations

Bound by UN Security Council mandatory resolutions only (IT Act 2000, FEMA). India has not imposed unilateral sanctions — see Section 2.

🇪🇺 EU Alignment

HostupCloud voluntarily screens against the EU Consolidated Sanctions List as best practice for EU customers.

1.1HostupCloud is legally required to comply with applicable economic sanctions and export control laws because of its UK (AL-GHANI NURNET LTD) and US (HOSTUPCLOUD, INC.) legal entities, regardless of where our customers are located.

1.2We screen all new customers, account changes, and transactions against applicable sanctions lists including the OFAC SDN List, UK Consolidated Sanctions List, EU Consolidated List, and UN Security Council Consolidated List.

1.3Export control regulations (US EAR/BIS, UK Export Control Order 2008, and India's SCOMET list) may restrict the export of certain technologies, encryption software, and technical data to specific countries or end-users.

1.4Hosting services, cloud computing, and SaaS are classified as technology exports under US EAR and equivalent regulations — they are not exempt.

1.5Violations of sanctions and export control laws can result in severe civil and criminal penalties for both HostupCloud and the customer.

1.6HostupCloud cannot provide services in circumvention of applicable sanctions, even if requested to do so by a customer, business partner, or governmental authority of a non-sanctioning jurisdiction (such as India).

2. India's Position on Sanctions

India does not maintain a comprehensive unilateral sanctions regime. The Government of India has not imposed independent sanctions on Russia, Iran, Cuba, Belarus, Syria, Venezuela, or Myanmar. This is an important distinction from the US, UK, and EU positions.

2.1India is a member of the United Nations and is legally bound to implement mandatory UN Security Council (UNSC) Consolidated List sanctions under UN Charter Article 25. These apply to entities such as certain North Korea–linked and Al-Qaida–linked designations.

2.2Beyond mandatory UNSC resolutions, India does not have domestic legislation equivalent to the US IEEPA/OFAC, UK Sanctions and Anti-Money Laundering Act 2018 (SAMLA), or EU Council Regulation powers to impose unilateral country-wide sanctions.

2.3India abstained on or voted against several UN General Assembly resolutions regarding the Russia–Ukraine conflict (2022–2025) and has continued to trade with Russia, Iran, and other countries that are sanctioned by the West. This reflects India's policy of strategic autonomy.

2.4India's export control framework (Foreign Trade Policy 2023, SCOMET list under the Foreign Trade (Development & Regulation) Act 1992) controls export of dual-use goods and technologies — but this is export control, not economic sanctions.

2.5The FEMA 1999 and RBI regulations restrict certain financial transactions but are not equivalent to OFAC asset-freezing sanctions.

2.6The sanctions restrictions listed in Section 3 of this page apply to HostupCloud because of its UK and US legal entities — NOT because the Government of India has imposed them. Indian customers asking 'why can't you serve Russia?' are subject to HostupCloud's US/UK compliance obligations, not Indian law.

India Implements

·UN Security Council Consolidated List (UNSCR mandatory)
·SCOMET export controls (dual-use goods)
·FEMA financial restrictions (limited)

India Does NOT Impose

·US OFAC-style comprehensive country sanctions
·UK OFSI-equivalent asset-freezing regimes
·Unilateral sanctions on Russia, Iran, Cuba, etc.

Why HostupCloud Still Restricts

·AL-GHANI NURNET LTD is a UK company (SAMLA 2018)
·HOSTUPCLOUD, INC. is a US company (IEEPA/OFAC)
·UK/US law applies regardless of data centre location

3. Sanctioned & Restricted Countries

The following countries are subject to comprehensive or sectoral sanctions that affect HostupCloud's ability to provide services. This list is updated periodically as sanctions regimes change.

Country / Territory	Sanctioning Authority	Restriction Level
North Korea (DPRK)	UN / US OFAC / UK OFSI / EU	Comprehensive
Iran	US OFAC / UK OFSI / EU	Comprehensive
Syria	US OFAC / UK OFSI / EU	Comprehensive
Cuba	US OFAC	Comprehensive
Russia	US OFAC / UK OFSI / EU (expanded 2024–2026)	Sectoral +
Belarus	US OFAC / UK OFSI / EU	Sectoral
Myanmar	US OFAC / UK OFSI / EU	Sectoral
Venezuela	US OFAC	Sectoral
Sudan	US OFAC / UN	Sectoral
Haiti	UN / US OFAC	Targeted

3.1Comprehensive sanctions: We cannot provide any services, accept any payments from, or engage in any commercial transactions with individuals or entities in comprehensively sanctioned countries.

3.2Sectoral sanctions: We may be able to provide limited services, but certain industries (finance, energy, defence) or specific entities within these countries are restricted.

3.3This list is not exhaustive. Additional countries or regions may be subject to restrictions based on evolving sanctions programmes. We recommend checking with legal@hostupcloud.com if you are uncertain.

3.4Using a VPN, proxy, or other technical means to disguise your true location and circumvent this policy is a material breach of our Terms and Conditions and may constitute a criminal offence in multiple jurisdictions.

This list reflects the sanctions landscape as of the Last Updated date above. Sanctions regimes change frequently. For the most current list, always refer to the official OFAC, UK OFSI, and EU sanctions databases. HostupCloud is not responsible for errors arising from sanctions changes made after the Last Updated date.

4. Restricted Persons & Entities

In addition to country-level restrictions, HostupCloud cannot provide services to individuals or entities that appear on any of the following restricted party lists, regardless of their country of residence:

OFAC SDN List

US Specially Designated Nationals and Blocked Persons List — individuals whose assets are blocked and with whom US persons are generally prohibited from dealing.

UK Consolidated Sanctions List

UK Office of Financial Sanctions Implementation (OFSI) list of individuals and entities subject to financial sanctions in the United Kingdom.

EU Consolidated List

European Union list of persons, groups, and entities subject to EU financial sanctions, arms embargoes, and travel bans.

UN Security Council Consolidated List

Individuals and entities subject to measures imposed by the UN Security Council, including asset freezes and travel bans.

4.1We screen customers against these lists at account creation, upon significant account changes, and periodically for existing accounts.

4.2If a customer's name or entity appears on a restricted party list, we are required to block the account and report to the relevant authority.

4.3If you believe you have been incorrectly matched to a restricted party list, contact legal@hostupcloud.com with proof of identity.

5. Prohibited Uses under Export Control

5.1Using HostupCloud services to develop, design, produce, or maintain weapons of mass destruction (nuclear, biological, chemical, or radiological weapons).

5.2Using HostupCloud infrastructure for military end-uses in countries subject to arms embargoes.

5.3Re-exporting or transferring HostupCloud services or access credentials to a sanctioned country or restricted person.

5.4Using HostupCloud services to circumvent export controls, sanctions, or embargoes of any jurisdiction.

5.5Hosting technology controlled under the Wassenaar Arrangement, US CCL (Commerce Control List), or Indian SCOMET list without the required export licences.

5.6Processing transactions or storing funds on behalf of sanctioned individuals or entities (money service business compliance).

6. Customer Obligations & Representations

By creating an account and using HostupCloud services, you represent and warrant that:

6.1You are not located in, incorporated in, or a national or resident of a comprehensively sanctioned country.

6.2You are not identified on the OFAC SDN List, UK Consolidated Sanctions List, EU Consolidated List, or UN Security Council Consolidated List.

6.3You will not use HostupCloud services in any manner that would violate applicable sanctions or export control laws.

6.4You will promptly notify HostupCloud if your circumstances change such that any of the above representations become inaccurate.

6.5If you are a reseller, you agree to pass these obligations on to your end-customers and to screen your customers against applicable sanctions lists.

6.6Providing false information about your location, identity, or end-use to circumvent this policy is a material breach that results in immediate account termination and may be reported to law enforcement.

7. Compliance & Enforcement

7.1Accounts found to be in violation of this policy will be immediately suspended pending investigation.

7.2HostupCloud will report violations to the appropriate regulatory authorities (OFAC, OFSI, FIU-IND) as required by law.

7.3Funds held in violating accounts may be blocked and reported to financial intelligence authorities.

7.4HostupCloud will not issue refunds for services terminated due to sanctions or export control violations.

7.5We conduct periodic compliance audits and update our screening processes as sanctions regimes change.

7.6If you have questions about whether a specific use case is permitted under this policy, contact legal@hostupcloud.com before purchasing.

Nothing in this policy constitutes legal advice. Sanctions and export control law is complex and fact-specific. If you are uncertain whether your use of HostupCloud services is compliant, consult your own legal counsel and/or contact the relevant regulatory authority (OFAC, OFSI, etc.) directly.

Compliance Enquiries

Questions about sanctions compliance or export controls? Contact our legal team before signing up.

legal@hostupcloud.com