Export Compliance Policy
Last updated: November 6, 2025
1. Overview
BrainPredict OÜ complies with all applicable export control laws and regulations, including:
- EU Dual-Use Regulation (EU) 2021/821 - Controls export of dual-use items
- Estonian Export Control Act - National implementation of EU regulations
- UN Security Council Resolutions - International sanctions and embargoes
- EU Sanctions Regulations - Restrictive measures against specific countries/entities
2. Export Classification
BrainPredict AI software may be subject to export controls:
Classification:
- Category: Dual-use items (software with AI/ML capabilities)
- ECCN: Under review (AI software classification evolving)
- Jurisdiction: Estonia (EU member state)
3. Restricted Countries and Entities
BrainPredict services are NOT available to customers in the following jurisdictions:
Embargoed Countries:
- Cuba
- Iran
- North Korea (DPRK)
- Syria
- Crimea, Donetsk, and Luhansk regions of Ukraine
- Any other country subject to comprehensive EU/UN sanctions
Additionally, BrainPredict will not provide services to:
- Entities on EU Consolidated Sanctions List
- Entities on UN Sanctions Lists
- Specially Designated Nationals (SDN) lists
- Denied Persons or Entity Lists
4. Customer Obligations
By using BrainPredict services, Customer represents and warrants that:
- Customer is not located in, organized under the laws of, or owned/controlled by persons in restricted countries
- Customer is not on any sanctions list or denied party list
- Customer will not use BrainPredict services for prohibited end-uses (weapons development, military applications)
- Customer will not re-export or transfer BrainPredict services to restricted parties
- Customer will comply with all applicable export control laws
- Customer will immediately notify BrainPredict if their status changes
5. Prohibited End-Uses
BrainPredict services may NOT be used for:
- Weapons Development: Design, development, or production of nuclear, chemical, or biological weapons
- Military Applications: Direct military or defense applications without proper authorization
- Missile Technology: Development of missile delivery systems
- Surveillance: Mass surveillance or human rights violations
- Terrorism: Any activity supporting terrorism or terrorist organizations
6. Screening Procedures
BrainPredict implements the following screening procedures:
- Customer Screening: All new customers screened against sanctions lists
- Ongoing Monitoring: Quarterly re-screening of existing customers
- Transaction Screening: High-value transactions screened for compliance
- IP Geolocation: Access blocked from restricted countries
7. Violations and Enforcement
If BrainPredict discovers a violation of export controls:
- Immediate Suspension: Account suspended immediately
- Investigation: Internal investigation conducted within 48 hours
- Reporting: Violations reported to Estonian authorities and EU Commission
- Termination: Account permanently terminated without refund
- Legal Action: BrainPredict reserves right to pursue legal remedies
8. Changes to Sanctions Lists
Export control regulations change frequently. BrainPredict will:
- Monitor sanctions lists daily for updates
- Notify affected customers within 24 hours of new restrictions
- Provide 7-day grace period for data export (if legally permitted)
- Suspend access immediately if required by law
9. Contact Information
For export compliance questions or to report violations:
BrainPredict OÜ - Compliance Officer
Email: privacy@brainpredict.ai
Phone: +372 6630414
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Jõe tn 3-314, 10151, Estonia
Registry Code: 17352111