Sanctions & Restricted Countries
Where trade is prohibited, where defense transfers are restricted, and what NexCommand AI must review before doing business.
Our no-trade commitment
NexCommand AI LLC is a U.S. company. We do not enter into transactions prohibited by applicable U.S. sanctions or export controls, including indirect supply through distributors, resellers or third countries. Restricted business must remain on hold unless a documented review establishes that it is lawful and that every required authorization is in place. Internal approval cannot override a government prohibition.
These requirements concern sales and purchases, software access and downloads, hardware, technical data, integration, training, support, payments and defense services. Their application depends on the product, parties, destination, end use and governing rule. A country listing alone is not a complete compliance determination.
There is no single U.S. government list that bans all trade with every sanctioned country. This page distinguishes broad restrictions from defense-specific, sectoral and targeted restrictions. Exceptions and licenses must be verified for the actual transaction; this page grants no authorization.
OFAC: who must comply · OFAC: current sanctions programs · Our Export Controls & Sanctions Policy
1. Broad country and territorial restrictions
Do not proceed with NexCommand business involving the destinations below without documented sanctions and export-control clearance. Broad prohibitions may have limited exemptions or authorizations.
| Destination | Restriction and required action | Official reference |
|---|---|---|
| Cuba | Broad OFAC embargo and EAR export controls. Ordinary commercial dealings must not proceed unless the specific activity is exempt or authorized under all applicable rules. | OFAC Cuba; 15 CFR 746.2 |
| Iran | Comprehensive OFAC trade restrictions and extensive EAR controls. Prohibited supply, services and dealings cannot proceed without applicable authorization; secondary sanctions can also affect non-U.S. parties. | OFAC Iran; 15 CFR 746.7 |
| North Korea (DPRK) | Extensive OFAC prohibitions and EAR licensing requirements. Treat sales, services, sourcing and payments as stopped pending specific legal clearance and any required authorization. | OFAC North Korea; 15 CFR 746.4 |
| Crimea; the so-called Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR) regions of Ukraine | Territorial sanctions and broad export restrictions. These are regions of Ukraine, not separate countries. Ukraine as a whole is not embargoed. Confirm the precise location and applicable territorial scope. | OFAC Ukraine/Russia; 15 CFR 746.6 |
2. Defense trade: ITAR destinations
For defense articles, technical data and defense services subject to ITAR, 22 CFR 126.1 establishes the following destination restrictions. Civilian trade is a separate determination. No controlled proposal, demonstration or transfer may proceed without the required DDTC approval.
General policy of denial
Belarus; Burma (Myanmar); China; Cuba; Iran; North Korea; Venezuela.
Country-specific denial policies and exceptions
Afghanistan; Central African Republic; Democratic Republic of the Congo; Eritrea; Haiti; Iraq; Lebanon; Libya; Nicaragua; Russia; Somalia; South Sudan; Sudan; Zimbabwe.
Consult each country paragraph: restrictions can depend on the recipient, armed group, security force or authorized purpose. These entries do not all impose identical countrywide bans.
Cyprus: restriction currently suspended
Cyprus remains listed, but its denial policy and proscribed status are suspended from 1 October 2026 through 30 September 2027. Ordinary licensing requirements still apply. Source: 22 CFR 126.1(r).
3. Other country programs and targeted restrictions
The following destinations have country-related OFAC programs or restrictions affecting particular persons, governments, sectors or activities. They are not all subject to a blanket ban on civilian trade. Any prohibited transaction is refused; other transactions require appropriate party, ownership, activity and export-control screening.
| Country or jurisdiction | Scope to review | Official reference |
|---|---|---|
| Russia and Belarus | Extensive export controls and party, financial and sectoral sanctions. Russia also has specific services prohibitions; neither entry should be read as a universal ban on every civilian transaction. | OFAC Russia; OFAC Belarus; EAR 746.8 |
| Venezuela | Government-related blocking, designated parties and activity-specific restrictions; licenses and their conditions must be checked. | OFAC Venezuela |
| Afghanistan; Burma (Myanmar); Central African Republic; Democratic Republic of the Congo; Iraq; Lebanon; Libya; Mali; Nicaragua; Somalia; South Sudan; Sudan; Yemen | Country-related programs target specified parties or activities. Program names do not themselves prohibit every transaction with all residents. | OFAC program directory and country pages |
| China and Hong Kong | Designated parties, Chinese military company securities restrictions, Hong Kong-related sanctions and relevant BIS controls. These are not a general OFAC civilian trade embargo on China or Hong Kong. | OFAC program directory; BIS Part 744 |
| Western Balkans | Regional targeted sanctions can affect persons across Albania, Bosnia and Herzegovina, Croatia, Kosovo, Montenegro, North Macedonia and Serbia. Residence in the region alone does not make a person blocked. | OFAC Balkans |
| Syria | The broad OFAC Syria sanctions program ended effective 1 July 2025. Targeted PAARSS and other sanctions remain. Syria is no longer in the current ITAR 126.1 destination tables; EAR 746.9 still requires separate licensing or a valid exception for covered exports. Do not treat sanctions relief as unrestricted supply. | OFAC PAARSS; EAR 746.9; ITAR 126.1 |
Sanctioned persons can be located in any country, including countries absent from these tables. Global terrorism, proliferation, cyber and human-rights programs apply independently of country lists. Check the complete current OFAC directory.
4. What applies to NexCommand products and services
- U.S. company obligations: OFAC rules apply to U.S. entities and their foreign branches. Working overseas, invoicing in another currency or using a reseller does not remove applicable prohibitions. OFAC applicability.
- M.AI, NORA and NEO AI: determine jurisdiction and classification for the actual hardware, software, encryption, source code and technical information. A defense customer or product name does not by itself establish ITAR status. U.S.-origin items can remain subject to EAR abroad; some foreign-made items are also covered. EAR scope.
- Russia IT and software services: covered IT consultancy/design and IT support or cloud services for enterprise-management and design/manufacturing software supplied from the U.S. or by U.S. persons are prohibited, subject to the determination's exclusions and authorizations. This requires particular review for ERP-related and NEO services. OFAC FAQ 1184.
- AI compute and sensitive end uses: assess GPUs, advanced-computing items, semiconductor restrictions, military/intelligence users and weapons-of-mass-destruction end uses. Destination, item specifications and knowledge of use can trigger controls. BIS end-use and end-user controls; BIS AI-training guidance.
- Remote access and support: review demos, repositories, downloads, technical training, field maintenance and cloud access for controlled disclosures, deemed exports/reexports and services restrictions before enabling access. On-premises delivery is also subject to review.
- Other applicable obligations: assess customer-country law, supplier license conditions, end-use assurances and retransfer limits alongside U.S. rules. For regulated military activity in Saudi Arabia, review GAMI policies and regulations and obtain required permissions. Review boycott-related contract requests under applicable U.S. antiboycott rules.
5. Screening and release requirements
- Identify the customer, beneficial owners, intermediaries, banks, final end user, installation location and intended use.
- Screen against the U.S. Consolidated Screening List and OFAC Sanctions List Search. Investigate possible matches and apply each list's actual restrictions.
- Check ownership: entities owned 50% or more in aggregate, directly or indirectly, by blocked persons are generally blocked even when unnamed. Check current BIS ownership rules separately. OFAC ownership guidance; BIS Part 744.
- Document product classification, destination and end-use restrictions, required licenses and the exact conditions of any exemption or exception. A clear name search alone does not authorize a transaction.
- Keep prohibited or unresolved business on hold. Do not route supply or payments through third countries to evade restrictions. Recheck before release, renewal, support or a change of parties, ownership, location or use.
Official sources and currency
Reviewed on 21 October 2026. The eCFR titles consulted displayed currency through 19 October 2026. Links lead to government publications and live agency guidance. This is a dated public summary, not a continuously updated screening service or an exhaustive list of all restrictions. Current law, license conditions and agency actions control.
For a transaction review, contact NexCommand AI with non-sensitive organization, destination and product details. Do not submit controlled technical data through the public website.