Export Control and Sanctions Compliance

Export Control and Sanctions Compliance

SAP software products and services are subject to the export control and sanctions laws of various countries, including without limitation, the laws of Germany, the European Union, and the United States of America.

Destination Restrictions

Taking into account overall business risks, SAP products and services are not available for export, reexport, transfer and/or use in the following countries/regions (subject to change without notice):

  • Crimea Region / Sevastopol

  • the so-called Donetsk People’s Republic (DNR) / Luhansk People’s Republic (LNR)

  • Cuba

  • Iran

  • North Korea

  • Syria

In the light of various tightened sanctions, some SAP products and services may not be available in Russia and Belarus.

Additionally, transactions with or related to certain destinations that pose an elevated export control or sanctions risk for SAP are subject to enhanced due diligence requirements, which may include authorization from the competent authorities. 
 

End-User Restrictions

SAP products and services are not available to entities and individuals with whom transactions are prohibited under applicable export control and sanctions laws, including those listed on any applicable sanctioned party lists (e.g., European Union Sanctions List, U.S. Specially Designated National (SDN) lists, U.S. Denied Persons List, BIS Entity List, United Nations Security Council Sanctions).
 

End-Use Restrictions

A license, authorization or other documentation may be required to proceed with transactions involving restricted end-uses, including:

  • Military end-uses that may implicate an arms embargo or similar restriction;

  • Certain civil nuclear end-uses; or

  • Industry-specific end-use restrictions, such as those related to certain energy and financial sectors. 

All such transactions are subject to enhanced due diligence and licensing determinations are made on a case-by-case basis.

SAP software and services may not be used for end-uses relating to the development, design, manufacture or production of nuclear, chemical or biological weapons (“Weapons of Mass Destruction”).
 

Export Classification

SAP products are classified for export under the Annex I of the Regulation 2021/821 ("EU Dual-use Regulation")/EC and U.S. Export Administration Regulations (US EAR).  A listing of U.S. and EU Export Control Classification Numbers (ECCN), applicable U.S. license exceptions and CCATS (where applicable) is available at the SAP ECCN MATRIX link below.  All information provided in the SAP ECCN Matrix may be subject to change without notice. Please contact ExportControlClassification@sap.com with any questions regarding the SAP ECCN Matrix.

SAP ECCN MATRIX

Disclaimer: This Export Control and Sanctions Compliance web page is for general informational purposes only and does not constitute legal advice by SAP as to any particular set of facts, nor does it represent any undertaking by SAP to keep the user advised as to all relevant U.S. or EU export control or sanctions laws. SAP encourages users to seek competent legal counsel for advice. (Note that there is no established schedule for updating this Web site.)  Further, any use of SAP’s classifications by any third party is without recourse to SAP and is at the third party’s own risk.  SAP is in no way responsible for any damages any third party may suffer as a result of using or relying upon such classifications.