Apple Debuts Trade Compliance Policy Site

Apple last week introduced a new ethics and compliance webpage, featuring a detailed outline of its trade compliance policies surrounding export controls and sanctions. A table of all Apple products provides their respective Export Control Classification Numbers and which destinations are blocked from receiving Apple products. The company said all its products qualify as mass market products and are subject to the Export Administration Regulations but are not controlled as dual-use goods by the Wassenaar Arrangement. Apple said some of its goods may be eligible for the Office of Foreign Assets Control’s Iranian General License No. D1 and Bureau of Industry and Security license exceptions related to Cuba. OFAC fined Apple about $465,000 in November 2019 after the company hosted, sold and helped transfer software applications and content belonging to a sanctioned company (see 1911250064).