Export Control & Trade Compliance Policy

Last updated: July 9, 2026

TerminalStreet LLC ("TerminalStreet," "we," "us," "our") is committed to complying with all applicable export control laws, trade sanctions, and international trade regulations. This Export Control & Trade Compliance Policy ("Policy") outlines our commitment to these legal requirements and provides guidance for our employees, contractors, partners, and customers.

1. Scope and Applicability

This Policy applies to all operations of TerminalStreet globally, including all services, products, technologies, and software we provide. It applies to:

• All employees, contractors, and representatives of TerminalStreet
• All customers and users of TerminalStreet's services
• All partners, vendors, and suppliers doing business with TerminalStreet
• All transactions and activities related to our AI, machine learning, data science, financial technology, blockchain, training, and outsourcing services

2. Key Regulatory Requirements

2.1 U.S. Export Controls

TerminalStreet complies with U.S. export controls, including:

• Export Administration Regulations (EAR): Administered by the U.S. Department of Commerce's Bureau of Industry and Security (BIS), covering "dual-use" items (goods, software, and technology that have both commercial and military applications)
• International Traffic in Arms Regulations (ITAR): Administered by the U.S. Department of State's Directorate of Defense Trade Controls (DDTC), covering defense articles, services, and technical data

Many of our services, particularly those involving advanced encryption, artificial intelligence, and certain blockchain technologies, may be subject to export controls under these regulations.

2.2 Economic and Trade Sanctions

TerminalStreet complies with economic and trade sanctions administered by:

• U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC): Administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals
• United Nations Security Council: Imposes international sanctions
• European Union: Administers EU sanctions programs
• Other national and international bodies: Various countries may maintain their own sanctions programs

2.3 Anti-Boycott Regulations

TerminalStreet complies with U.S. anti-boycott laws that prohibit U.S. companies from participating in foreign boycotts not sanctioned by the United States, such as the Arab League boycott of Israel.

3. Restricted Parties and Territories

3.1 Restricted Parties

TerminalStreet prohibits transactions with parties on restricted party lists, including but not limited to:

• The U.S. Department of Treasury's Specially Designated Nationals and Blocked Persons List (SDN List)
• The U.S. Department of Commerce's Denied Persons List, Entity List, and Unverified List
• The U.S. Department of State's Debarred List
• The EU Consolidated List of Sanctions
• The UN Consolidated List
• Other applicable national restricted party lists

We conduct regular screening of customers, partners, and transactions against these lists to ensure compliance.

3.2 Embargoed Countries and Territories

TerminalStreet does not provide services or engage in transactions with comprehensively sanctioned countries or territories, which currently include:

• Cuba
• Iran
• North Korea
• Syria
• The Crimea, Donetsk, and Luhansk regions of Ukraine
• Any other regions subject to comprehensive sanctions

We employ technical measures, including IP blocking and other access controls, to restrict access to our services from these locations. We also prohibit the use of VPNs or other methods to circumvent these restrictions.

4. Technology and Service-Specific Controls

4.1 AI and Machine Learning Technologies

Certain AI and machine learning technologies may be subject to export controls due to their potential dual-use applications. TerminalStreet implements the following controls:

• Screening of AI use cases for potential military, surveillance, or other sensitive applications
• Restrictions on the training of certain types of AI models that could have weapons-related applications
• Limitations on the transfer of certain advanced AI technologies to specific countries
• Review of end-users and end-uses for AI systems with high computational capabilities

4.2 Encryption Technologies

Many of our services incorporate encryption, which is subject to export controls in numerous jurisdictions. We implement the following measures:

• Classification of our encryption items under the EAR
• Obtaining required authorizations for the export of encryption items
• Compliance with encryption registration and reporting requirements
• Verification that encryption capabilities are not available to prohibited end-users or for prohibited end-uses

4.3 Blockchain and Cryptocurrency Technologies

Blockchain technologies and cryptocurrencies may be subject to export controls and sanctions regulations. TerminalStreet implements the following controls:

• Screening of blockchain applications and smart contracts for sanctions compliance
• Implementation of KYC (Know Your Customer) and AML (Anti-Money Laundering) procedures for applicable services
• Monitoring for suspicious transactions that may involve sanctioned entities or territories
• Restrictions on the development of certain blockchain applications for prohibited end-users or end-uses

4.4 Financial Technology Services

FinTech services may be subject to additional financial sanctions and export controls. TerminalStreet implements the following controls:

• Enhanced due diligence for financial technology services
• Screening of financial transactions against sanctions lists
• Monitoring for suspicious financial activity
• Compliance with applicable financial regulations in all jurisdictions where we operate

5. Due Diligence and Risk Mitigation Procedures

5.1 Customer and Transaction Screening

TerminalStreet conducts appropriate due diligence on customers, partners, and transactions, including:

• Initial screening of all new customers against restricted party lists
• Regular re-screening of existing customers against updated lists
• Enhanced due diligence for customers in high-risk jurisdictions or industries
• Verification of end-uses and end-users for sensitive technologies
• IP address verification to prevent access from embargoed territories

5.2 Red Flags and Escalation Procedures

TerminalStreet maintains a list of "red flags" that may indicate potential export control or sanctions risks. These include:

• Reluctance to provide information about the end-use or end-users of our technologies
• Unusual payment terms or payment routes
• Orders for items unusual for the customer's business
• Delivery requests to freight forwarders or addresses that are inconsistent with the stated end-use
• Evidence that a customer may be using VPNs or other methods to circumvent geographic restrictions

When red flags are identified, employees must escalate these issues to our Trade Compliance team for review before proceeding.

6. Technical Implementation and Enforcement

6.1 Automated Technical Controls

TerminalStreet implements comprehensive technical measures to ensure compliance with export control and sanctions regulations:

• Real-Time IP Geolocation Blocking: Automated blocking of access from embargoed territories using industry-standard IP geolocation databases updated every 4 hours
• Dynamic Sanctions Screening: Real-time screening against all major sanctions lists (OFAC SDN, BIS Entity List, EU Consolidated List, UN Consolidated List) with updates every 24 hours
• API Rate Limiting and Monitoring: Advanced rate limiting and behavioral analysis to detect suspicious usage patterns that may indicate sanctions evasion attempts
• VPN and Proxy Detection: Advanced detection and blocking of VPN, proxy, and Tor traffic from restricted territories
• Automated Transaction Monitoring: AI-powered monitoring of financial transactions and service usage patterns for sanctions compliance

6.2 Comprehensive Audit Trail

All export control and sanctions-related activities are logged and maintained in tamper-evident audit trails:

• User Access Logs: Complete logs of user access attempts, including IP addresses, timestamps, geolocation data, and access decisions
• Screening Results: Detailed records of all sanctions list screening results, including match scores and resolution decisions
• Transaction Records: Comprehensive logging of all service transactions, including user identification, service details, and compliance verification status
• System Configuration Changes: Audit trail of all changes to export control and sanctions compliance system configurations
• 5-Year Retention: All compliance-related logs are retained for a minimum of 5 years in secure, encrypted storage systems

6.3 Automated Compliance Monitoring

TerminalStreet employs advanced automated monitoring systems to ensure ongoing compliance:

• Real-Time Alerts: Immediate alerts for potential sanctions violations, unusual access patterns, or system configuration changes that could impact compliance
• Weekly Compliance Reports: Automated generation of compliance status reports including screening statistics, blocked access attempts, and system performance metrics
• Quarterly Technology Assessments: Comprehensive quarterly reviews of all technical compliance systems, including penetration testing and effectiveness evaluations
• Regulatory Update Integration: Automated integration of regulatory updates and sanctions list changes into our compliance systems
• False Positive Minimization: Machine learning algorithms to continuously improve accuracy and reduce false positive compliance alerts

6.4 Service-Specific Technical Controls

Different services implement specialized technical controls based on their export control risk profile:

• AI/ML Services: Automated analysis of training data sources, model architectures, and intended use cases to identify potential dual-use applications
• Blockchain Services: Real-time transaction monitoring and address screening against known sanctioned cryptocurrency addresses
• Financial Services: Enhanced KYC/AML integration with real-time financial intelligence screening
• Encryption Services: Automated classification and export control determination for encryption components based on strength and implementation
• Custom Development: Mandatory export control review workflow for all custom development projects with automated risk scoring

7. Compliance Program Elements

7.1 Management Commitment

TerminalStreet's leadership is committed to compliance with export control and sanctions laws. This commitment is demonstrated through:

• Allocation of adequate resources to the compliance program
• Regular review of compliance policies and procedures
• Integration of compliance considerations into business decisions
• Creating a culture where compliance is prioritized over business opportunities

7.2 Training and Awareness

TerminalStreet provides regular training on export control and sanctions compliance to:

• All employees, with role-specific training for those in sales, engineering, product development, and support roles
• Contractors and consultants who interact with our technologies or customers
• Partners and resellers who distribute or integrate our services

Training materials are regularly updated to reflect changes in regulations and our product offerings.

7.3 Record Keeping

TerminalStreet maintains records related to export control and sanctions compliance for a minimum of five years, including:

• Customer screening results
• Export classifications of our technologies
• Export licenses and authorizations
• Documentation of compliance decisions and cases
• Training records

7.4 Internal Audits and Monitoring

TerminalStreet conducts regular internal audits of our export control and sanctions compliance program to:

• Identify potential compliance gaps or weaknesses
• Test the effectiveness of existing controls
• Ensure consistent application of compliance procedures
• Verify that our technical controls for geographic restrictions are functioning properly

Audit findings are reported to management and addressed through corrective action plans.

8. Violation Reporting and Consequences

8.1 Reporting Suspected Violations

All employees, contractors, customers, and partners are encouraged to report suspected violations of this Policy or applicable export control and sanctions laws to:

• Their manager or point of contact at TerminalStreet
• Our Trade Compliance team at [email protected]

TerminalStreet prohibits retaliation against anyone who reports suspected violations in good faith.

8.2 Consequences of Violations

Violations of export control and sanctions laws can result in severe consequences, including:

• Civil and criminal penalties for both individuals and the company
• Loss of export privileges
• Reputational damage
• Termination of employment or business relationships

TerminalStreet takes violations seriously and will cooperate with authorities in the investigation of any alleged violations.

9. Updates and Additional Information

This Policy will be reviewed and updated regularly to reflect changes in regulations, our business, or best practices. The current version of this Policy is always available on our website.

For questions about this Policy or specific export control or sanctions compliance matters, please contact our Trade Compliance team at [email protected].

10. Customer Responsibilities

Customers and users of TerminalStreet services are responsible for:

• Complying with all applicable export control and sanctions laws when using our services
• Not accessing our services from embargoed countries or territories
• Not transferring, exporting, or re-exporting our services to prohibited parties or territories
• Providing accurate information about end-uses and end-users when requested
• Implementing appropriate controls to ensure their use of our services complies with export control and sanctions laws

Failure to meet these responsibilities may result in termination of access to TerminalStreet services.