Compliance Center

Advanced Integrated Circuit & Computing

Headquarters Compliance Certification

Issued by Vipera LLC in connection with the sale, distribution, and onward transfer of advanced computing products.

Document Version 2026.1
Confidential Compliance Document

Section 01

Regulatory Background

This certification supports Vipera LLC's compliance with United States export control laws applicable to advanced integrated circuits, computers, and computing-related items, including but not limited to the Export Administration Regulations (EAR, 15 CFR Parts 730–774) and the advanced- computing controls announced by the U.S. Bureau of Industry and Security (BIS) in 88 Fed. Reg. 73458 (October 25, 2023), as amended, and the Framework for Artificial Intelligence Diffusion published January 13, 2025.

For purposes of this document, "Restricted IC Product" means any item that is (a) classified under ECCN 3A090, 4A090, or any related ECCN covering advanced integrated circuits, computers, electronic assemblies, or components that incorporate such advanced ICs, or (b) otherwise subject to export licensing requirements under EAR Part 744 or Country Group restrictions in Supplement No. 1 to EAR Part 740.

Section 02

Restricted Destinations

Vipera LLC will not export, re-export, transfer (in-country), or facilitate the supply of Restricted IC Products to or within the following destinations without first obtaining the authorizations required by U.S. law.

Comprehensively Embargoed / Country Group E:1, E:2

CubaSyriaCrimea / Donetsk / Luhansk regions of UkraineIranRussiaNorth Korea (DPRK)Belarus

Arms-Embargoed / Country Group D

D:5 and D:1, D:3, D:4 — advanced-computing controls apply.

China (PRC)Democratic Republic of the CongoMacauVenezuelaBurma (Myanmar)CambodiaCentral African RepublicEritreaHaitiIraqLebanonLibyaNicaraguaSomaliaSouth SudanSudanZimbabwe

This list reflects current U.S. regulatory designations and is subject to change as BIS, OFAC, and related agencies update country-group assignments, sanctions programs, and embargo determinations. Vipera LLC screens each transaction against the live versions of these lists at the time of order acceptance.

Section 03

Vipera LLC's Compliance Certification

Vipera LLC hereby certifies, in connection with its supply, distribution, and sale of advanced computing products, that:

1

Vipera LLC maintains an active export-compliance program covering screening, training, recordkeeping, and senior-management oversight, consistent with the BIS Export Compliance Program guidance.

2

Vipera LLC screens every counterparty, end-user, and shipment destination against the U.S. Department of Commerce Entity List, Denied Persons List, Unverified List, and the OFAC Specially Designated Nationals List, prior to acceptance of any order for Restricted IC Products.

3

Vipera LLC will not knowingly export, re-export, transfer, or divert any Restricted IC Product to a destination, end-user, or end-use prohibited under U.S. export controls, including the prohibited end-uses set out in EAR §744.

4

Vipera LLC does not engage in transactions intended to circumvent the controls established under 88 Fed. Reg. 73458 (October 25, 2023), the AI Diffusion Framework (January 13, 2025), or any successor regulation.

5

Vipera LLC requires its downstream counterparties, distributors, and end-customers to provide compliance representations equivalent to those set out in this Certification before any Restricted IC Product is released.

6

Vipera LLC promptly notifies its upstream suppliers of any material change to its corporate ownership, headquarters jurisdiction, or operating footprint that could affect this Certification.

Section 04

Counterparty Representation

Complete the information below on behalf of your company. Fields marked with an asterisk are required.

01

Company Information

Provide the legal and registered headquarters information for the company.

Registered Headquarters Address

02

Counterparty Representation

The Company represents the following to Vipera LLC as a condition of the supply of any Restricted IC Product.

The Company's headquarters and principal place of business are not located in any of the Restricted Destinations listed in Section 2.

No person or entity owning, directly or indirectly, 10% or more of the Company is headquartered, organized, or ordinarily resident in any Restricted Destination.

The Company is not listed on, nor owned 50% or more in the aggregate by parties listed on, the Entity List, Denied Persons List, Unverified List, OFAC SDN List, or any equivalent U.S. Government restricted-party list.

03

Continuing Obligations & Notification

These acknowledgements apply to every transaction involving Restricted IC Products.

04

Acknowledgements

Please review and acknowledge each statement before submitting the certification.

05

Authorized Signatory

The person signing below must be duly authorized to bind the Company.

By entering your name above, you acknowledge that it represents your electronic signature for this Certification.

06

Additional Information / Explanatory Notes

Optional. Use this section to provide information such as recent changes to HQ location, ownership disclosures, or discrepancies in public materials.

07

Final Certification

Please review all information carefully before submitting.

Security verification

By submitting this Certification, you confirm that the information provided is accurate and that you have authority to make these representations on behalf of the Company.

Section 05

Continuing Obligations & Notification

The Company acknowledges that its representations under this Certification are continuing and apply to every transaction with Vipera LLC involving Restricted IC Products. The Company will promptly notify Vipera LLC in writing of any change in its ownership structure, headquarters jurisdiction, operating locations, or restricted-party status that could affect any representation made above.

The Company will maintain records of each Restricted IC Product transaction for the period required by 15 CFR Part 762 and will make such records available to Vipera LLC and to U.S. Government authorities on lawful request.

Section 06

Acknowledgements

Future availability of any specific advanced IC, computer, or computing assembly may be affected by U.S. regulatory changes; Vipera LLC does not guarantee identical or compatible replacements for items rendered unavailable due to such changes.

Information provided in this Certification will be used by Vipera LLC to comply with U.S. export-control and trade laws, and may be shared with upstream suppliers, OEMs, and U.S. Government authorities to that extent.

The Company has the lawful authority to sign this Certification and to bind the Company to the representations and obligations herein.

Vipera LLC | Confidential | Compliance

Advanced IC & Computing | HQ Compliance Certification