Sanctions & Export Control
What is screened, what is emphatically not, and what to do about a false match.
We are bound by US sanctions and export-control law, and by the equivalent rules where we operate. This page says exactly what that means for you, because a refusal without an explanation looks like discrimination and this is not that.
What is screened
- Where you are. Accounts cannot be opened from comprehensively embargoed jurisdictions: CU, IR, KP, SY. We check the country you declare and, as a second signal, whether the network address you sign up or sign in from belongs to one of those countries. Payments are refused from an account last signed in from one. The address check works out only the country, on our server, and we keep only the result (the country, if it is one of them). IP Geolocation by DB-IP, licensed CC BY 4.0.
- Names against the sanctions list. Names are screened against the OFAC Specially Designated Nationals list before money moves. A close match (the same words in another order, an extra middle name, a near spelling) holds the payment until a person on our team has looked; it never refuses you on its own.
What is not screened
Not your ethnicity, your ancestry, your religion, your language, or your name's origin. OFAC designates named persons and embargoes named places. It has never designated an ethnicity, and screening on one would be a discrimination problem on top of being useless. The country we ask for is where you are — it selects the applicable law. It is not your nationality and not where you are from.
When the list is unavailable
Money paths fail closed: if the sanctions list cannot be loaded, transactions that would move real money are refused rather than allowed through unscreened.
Export control
This service includes encryption. Exporting it, or using it, may be restricted where you are. You are responsible for complying with the rules that apply to you. Our own export self-classification with the US Bureau of Industry and Security is not yet filed; that filing is required before app-store distribution and is listed as outstanding rather than quietly omitted.
If you think a refusal is wrong
Sanctions screening on names produces false matches; common names match often. Write to legal@whinchat.app and a person will look at it. We do not tell you which check you failed, because that would turn this page into a way to test names against the list.
What has changed
23 October 2026 · version 3
- Where you are — the address check now uses a table of every country's address ranges, because the app can also be closed to other countries (see the Privacy Policy). It still works out only the country, on our server, and nothing is kept unless it stops you.
11 October 2026 · version 2
- Where you are — besides the country you declare, the network address you sign up or sign in from is checked against the embargoed countries (IP Geolocation by DB-IP).
- Names — close matches (another word order, an extra middle name, a near spelling) hold a payment until a person has looked; they never refuse it on their own.
5 August 2026 · version 1
- First published.