Export Control & Sanctions.

Last updated: August 16, 2026

1. Our commitment

empowered.guru, LLC will not, directly or indirectly, provide any service, software, technology, model, or training to any person, entity, or destination where doing so would violate U.S. export-control or sanctions law, or any equivalent foreign regime applicable to the engagement.

2. What this covers

This policy applies to all services we provide, including consulting, managed services, private-LLM deployments, and the transfer of any software, model weights, technical data, or training to any party in any country.

3. U.S. law

Our baseline program is designed to comply with the following U.S. regimes, as amended and supplemented from time to time:

• EAR: the Export Administration Regulations (15 C.F.R. Parts 730-774), administered by the Bureau of Industry and Security (BIS), including the Commerce Control List (CCL), Export Control Classification Numbers (ECCNs), and license requirements.
• ITAR: the International Traffic in Arms Regulations (22 C.F.R. Parts 120-130), administered by the Directorate of Defense Trade Controls (DDTC), including the U.S. Munitions List (USML). We do not generally provide ITAR-controlled services; if a SoW involves ITAR items, the engagement is reviewed and the SoW explicitly addresses it.
• OFAC sanctions: administered by the Office of Foreign Assets Control, including the Specially Designated Nationals (SDN) list, the Foreign Sanctions Evaders list, the Sectoral Sanctions Identifications list, and the country-specific sanctions programs (Cuba, Iran, North Korea, Syria, the Crimea/Donetsk/Luhansk regions, and others as updated).
• CFIUS: for transactions involving foreign persons and U.S. businesses in critical technology, critical infrastructure, or sensitive personal data, we coordinate with outside counsel before closing any transaction that may trigger CFIUS review.

4. Foreign law

Where the engagement involves exports, re-exports, or in-country transfers governed by a non-U.S. regime (for example, EU Dual-Use Regulation 2021/821, UK Strategic Export Control, Wassenaar, MTCR, or Australia's DSGL), the SoW identifies the regime and the additional obligations that apply. We do not represent expertise in every regime; we engage qualified local counsel where required.

5. Items we provide

The following categories of items may be subject to export controls:

• Open-weight models distributed under their own licenses (Qwen, Llama, Mistral, DeepSeek). Most open weights are publicly available and not on the CCL, but specific weights may have additional restrictions (for example, Llama Community License, Qwen's use-based restrictions).
• Fine-tuned models we develop for you are Deliverables under the MSA; we treat them as the Client's property and pass through the upstream license.
• Software we develop, including agent runtimes, RAG pipelines, training code, and orchestration tooling. Where the SoW specifies an ECCN, we follow it; absent an ECCN, we default to EAR99.
• Encryption. Some deliverables include cryptographic functionality. We classify per Category 5 Part 2 of the CCL and report to BIS where required.
• Technical data provided to non-U.S. persons located in the U.S. or abroad is treated as a deemed export / re-export and screened accordingly.

6. Denied-party screening

Before onboarding a client or counterparty, and periodically during an engagement, we screen:

• The legal entity and ultimate beneficial owners.
• The principals, directors, and officers of the entity.
• The country and region of incorporation and operation.
• The end-use and end-user of the deliverables.

Screening sources include OFAC's SDN list, BIS's Entity List and Denied Persons List, the U.S. Department of Commerce's Unverified List, the DDTC's AECA Debarred List, the U.S. Department of State's designated terrorist organizations list, and equivalent foreign lists where the engagement requires them. A "hit" pauses the engagement and is escalated to outside counsel.

7. End-use and end-user

We will not provide services or items where we know or have reason to know that the end-use is:

• Military end-use in a country subject to a U.S. arms embargo.
• WMD proliferation (nuclear, chemical, biological, or missile).
• Surveillance, digital repression, or human-rights abuses.
• Any other use prohibited by the EAR, ITAR, or applicable foreign regime.

8. AI-specific notes

The export-control status of AI models and AI-enabled services is evolving. We follow BIS's January 2025 framework for advanced AI model weights (the "AI Diffusion Rule") and any successor or replacement regulation. Where a model falls inside the controlled category, we will not transfer it to a destination or end-user that requires a license we do not hold.

We do not provide services for, or to, entities on OFAC's SDN list or equivalent. We will not fine-tune or deploy models for end-uses covered by Executive Order 14110 (Safe, Secure, and Trustworthy Development and Use of AI) or its successors where prohibited.

9. Client obligations

You agree (a) to provide accurate end-use and end-user information, (b) not to re-export or re-transfer deliverables in violation of applicable law, (c) to notify us of any change in your status (for example, becoming owned or controlled by a person on a denied-party list) within 5 business days, and (d) to maintain your own export compliance program sufficient to satisfy your obligations.

10. Reporting and recordkeeping

We retain records of export classifications, screening results, license determinations, and end-use statements for at least five years from the date of the transaction, per 15 C.F.R. § 762.6. We report apparent violations to BIS, OFAC, or DDTC as required and cooperate with their inquiries.

11. Training

Personnel involved in client onboarding, SoW drafting, and trade compliance receive annual training on EAR, OFAC, and AI-specific export controls. Records of training are retained for five years.

12. Contact

Export-control questions: trade-compliance@empowered.guru. Suspected violations: legal@empowered.guru.

See also our Anti-Bribery, Responsible AI, and AI Disclosure policies.