Export Compliance
Version 1.0MPC Holding, Inc. and its subsidiary Ti22, LLC (“Ti22”) are committed to full compliance with U.S. export control and economic sanctions laws, including the Export Administration Regulations (“EAR”) administered by the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”), and the sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).
Product Classifications
| OTIG Item | ECCN | Authorization |
|---|---|---|
| OTIG Transit Node software (binary) | 5D002.c.1 | License Exception ENC, 15 C.F.R. § 740.17(b)(1) |
| OTIG Transit Node appliance (hardware) | 5A002.a | License Exception ENC, § 740.17(b)(1) |
| OTIG Transit Node source code | 5D002.c.1 | License Exception ENC, § 740.17(b)(2)(i)(B) |
| OTIG Transit Node encryption technology | 5E002.a | License Exception ENC, § 740.17(b)(2)(iv)(B) |
| OTIG Admin software (binary & source code) | EAR99 | No license required for most destinations |
| OTIG Admin encryption technology | EAR99 | No license required for most destinations |
BIS CCATS Reference: G199601, issued March 16, 2026.
Restricted Destinations
Ti22 does not export, reexport, transfer, or provide services (including SaaS access) to any person or entity located in, or ordinarily resident in, the following jurisdictions:
- Cuba, Iran, North Korea, and Syria
- The Crimea, so-called Donetsk People’s Republic, and so-called Luhansk People’s Republic regions of Ukraine
- The Russian Federation and Belarus, subject to narrow exceptions
- The government or governmental instrumentalities of Venezuela
Restricted Parties
Ti22 will not engage in transactions with any party identified on:
- The BIS Denied Persons List, Entity List, or Unverified List
- The OFAC Specially Designated Nationals and Blocked Persons List, including any entity owned 50% or more by one or more SDNs
- The BIS Military End User List, or any foreign entity owned 50% or more by listed persons under the BIS Affiliates Rule
- Any party on OFAC’s Consolidated Non-SDN List, absent advance counsel approval
Customers and partners may self-screen using the U.S. Government’s Consolidated Screening List at https://www.trade.gov/data-visualization/csl-search.
Prohibited End Uses and End Users
Regardless of destination, OTIG items may not be used, and Ti22 will not knowingly support their use, for:
- Any “military-intelligence end use” or by a “military-intelligence end user” in Belarus, Burma, Cambodia, China (including Hong Kong and Macau), Russia, Venezuela, Cuba, Iran, North Korea, or Syria
- Any “military end use” or by a “military end user” in Russia, Belarus, or Iraq
- Any activity supporting the proliferation of nuclear, chemical, or biological weapons, or missile or unmanned aerial vehicle systems
- Any transaction the exporter knows or has reason to know will result in a violation of U.S. law
Government End-User Limitations
OTIG proprietary source code (ECCN 5D002) and encryption technology (ECCN 5E002) may not be exported to any “government end user” located or headquartered outside the License Exception ENC Favorable Treatment Countries identified in Supplement No. 3 to Part 740 of the EAR. 5E002 encryption technology also may not be exported to end users in Country Group D:1, E:1, or E:2.
Destination Control Statement
Physical shipments of OTIG hardware or software media are accompanied by the following Destination Control Statement required by 15 C.F.R. § 758.6(a)(1):
“These items are controlled by the U.S. Government and authorized for export only to the country of ultimate destination for use by the ultimate consignee or end-user(s) herein identified. They may not be resold, transferred, or otherwise disposed of, to any other country or to any person other than the authorized ultimate consignee or end-user(s), either in their original form or after being incorporated into other items, without first obtaining approval from the U.S. government or as otherwise authorized by U.S. law and regulations.”
Geographic Access Controls
Ti22 implements IP-address-based access controls to prevent client devices located in embargoed jurisdictions from accessing the Ti22 platform, download sites, and related online resources.
Reporting Suspected Violations
If you become aware of a suspected violation of these policies or of U.S. export control or sanctions laws in connection with OTIG items, please contact [email protected] promptly so we can investigate and, if appropriate, disclose to BIS or OFAC.
Changes to This Notice
The EAR and U.S. sanctions programs are dynamic. Ti22 reviews this notice at least annually and when material product changes occur, and we encourage customers to revisit this page regularly.
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