Export Control Policy
Last Updated: 10/20/2025
This software includes advanced encryption technology, and certain actions involving it are prohibited by federal law. Engaging in restricted activities, even unintentionally, may result in criminal penalties. A lack of knowledge of these laws does not excuse liability. Please read the following information carefully before installing or using this software.
You are prohibited from exporting this software to countries restricted by the U.S. Commerce Control List, which currently includes:
Cuba
Iran
Myanmar
North Korea
Sudan
Syria
In addition, the VPN Lightning service and software must not be accessed, distributed, or used by the following individuals or entities:
Belarus: Individuals undermining democratic institutions or processes (including President Alexander Lukashenko and other related officials).
Democratic Republic of the Congo: Persons contributing to ongoing conflict within the region.
Former Yugoslavia: Individuals threatening peace and stability in the Western Balkans or regions of the former Yugoslavia.
Iraq: Persons or organizations associated with the former Saddam Hussein regime, or those involved in acts of violence that disrupt peace, hinder Iraq’s political and economic reform, or interfere with humanitarian efforts.
Lebanon: Individuals undermining the sovereignty or democratic processes of Lebanon.
Libya: Persons linked to the former regime of Muammar Gaddafi.
Russia: Individuals involved in human rights violations, including those connected to the detention and death of Sergei Magnitsky, or actions that compromise the peace, territorial integrity, and democratic institutions of Ukraine. This includes officials managing territories without the consent of Ukraine’s central government, and senior Russian officials close to President Vladimir Putin.
Somalia: Persons contributing to armed conflict in Somalia.
Ukraine: Individuals or entities threatening peace, stability, or democratic operations within Ukraine, including those governing regions without central authority approval, and senior Russian officials connected to President Vladimir Putin.
Venezuela: Government officials implicated in human rights abuses or involved in the 2014–2015 protests as cited by the U.S. government.
Yemen: Individuals or organizations threatening peace, stability, or national security in Yemen.
Zimbabwe: Persons undermining democratic institutions or governance in Zimbabwe, including current government officials.
This list is subject to change. For the most recent version, please visit http://www.bis.doc.gov/index.php/forms-documents/doc_download/743-740. The export restriction applies not only to sending the software electronically to these nations but also to physically transporting a device containing this software into or through any restricted country.
Regardless of location, including within the United States, you may not transfer this software or any device containing it to individuals, organizations, or companies listed on the Denied Parties List. You can review the current list at http://www.bis.doc.gov/index.php/forms-documents/doc_view/452-supplement-no-1-to-part-740-country-groups. Such a transfer qualifies as a “deemed export” under U.S. Export Administration Regulations.
Before transferring this software or a device containing it to any foreign national, you must first verify that the recipient is not listed on the Denied Parties List. If the individual or entity is included, contact the U.S. Department of Commerce, Information Technology Controls Division, at (202) 482-0707 to apply for an export license. Any transfer made without proper authorization is a felony offense.
By downloading or using this software, you acknowledge and accept full personal responsibility for compliance with U.S. export control laws. You agree to secure all necessary export licenses prior to transferring or distributing any copies of this software.