Sanctions Policy

EveryoneCounts provides a connection between all peoples seeking an abundant life. When you use EveryoneCounts’ services (referred to as “Services”), you are responsible for complying with this policy, regardless of your location.

This policy is a part of our Terms of Use. By using any of our Services, you agree to this policy and our Terms of Use.

As a company based in the US, EveryoneCounts must comply with economic sanctions and trade restrictions, including those implemented by the Office of Foreign Assets Control (“OFAC”) of the US Department of the Treasury. This means that EveryoneCounts or anyone using our Services cannot take part in transactions that involve designated people, places, or items that originate from those places, as determined by agencies like OFAC.

This policy applies to anyone that uses our Services, regardless of their location. It is up to you to familiarize yourself with these restrictions.

For example, these restrictions generally prohibit, but are not limited to, transactions involving:

1. Certain geographic areas or any individual or entity operating or residing in those places;
2. Individuals or entities identified on sanctions lists such as OFAC’s Specially Designated Nationals (“SDN”) List or Foreign Sanctions Evaders (“FSE”) List;
3. Nationals of Cuba, regardless of location, unless citizenship or permanent residency outside of Cuba has been established; and
4. Items originating from areas including Cuba, North Korea, Iran, or Crimea, with the exception of informational materials such as publications, films, posters, phonograph records, photographs, tapes, compact disks, and certain artworks.

In order to protect our community and marketplace, EveryoneCounts may take steps to ensure compliance with sanctions programs. For example, EveryoneCounts may prohibit members from using their accounts while in certain geographic locations. If we have reason to believe you are operating your account from a sanctioned location, such as any of the places listed above, or are otherwise in violation of any economic sanction or trade restriction, we may suspend or terminate your use of our Services. Members are generally not permitted to list, buy, or sell items that originate from sanctioned areas. This includes items that pre-date sanctions since we have no way to verify when they were actually removed from the restricted location. EveryoneCounts reserves the right to request that sellers provide additional information, disclose an item’s country of origin in a listing or take other steps to meet compliance obligations. We may disable listings or cancel transactions that present a risk of violating this policy.

In addition to complying with OFAC and applicable local laws, EveryoneCounts members should be aware that other countries may have their own trade restrictions and that certain items may not be allowed for export or import under international laws. You should consult the laws of any jurisdiction when a transaction involves international parties.

Finally, EveryoneCounts members should be aware that third-party payment processors, such as PayPal, may independently monitor transactions for sanctions compliance and may block transactions as part of their own compliance programs. EveryoneCounts has no authority or control over the independent decision-making of these providers.

The economic sanctions and trade restrictions that apply to your use of the Services are subject to change, so members should check sanctions resources regularly. For legal advice, please consult a qualified professional.

Resources: US Department of the Treasury; Bureau of Industry and Security at the US Department of Commerce; US Department of State.

Last updated on August 25, 2021