SANCTIONS AND GEO-BLOCKING POLICY

This Policy describes how Obmify restricts access to its platform from certain jurisdictions subject to international sanctions, trade embargoes, or heightened compliance risks. This document explains the Platform's operational approach to sanctions compliance and territorial access controls.

This Policy should be read in conjunction with the Platform's Terms of Use, particularly Section 13 (Sanctions and Prohibited Jurisdictions) and Section 5 (User Eligibility).

Where applicable, the Platform operates in compliance with the following sanctions regimes:

• the UK Sanctions List — Extended to the British Virgin Islands through the Russia Sanctions (Overseas Territories) Order 2020 (S.I. 2020/1571);
• UN Sanctions — Financial sanctions, asset freezes, and trade embargoes imposed by United Nations Security Council (UNSC) resolutions;
• EU Sanctions (for reference) — Council Regulation (EU) No 833/2014 and subsequent amendments, applied where Platform interactions involve EU-connected parties;
• BVI Regulatory Oversight — Compliance monitored by the BVI Governor's Office, Financial Services Commission (FSC), and Financial Investigation Agency (FIA).

Access to and use of the Platform is strictly prohibited for any person or entity that is:

• (a) listed on any of the following sanctions lists, or 50% or more owned or controlled by any person or entity so listed:
  • the UK Sanctions List;
  • the UN Consolidated Sanctions List;
  • the EU Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions;
  • the OFAC Specially Designated Nationals and Blocked Persons List (SDN List);
  • any other sanctions list maintained by any Sanctions Authority in any jurisdiction.
• (b) acting on behalf of, for the benefit of, or at the direction of any person or entity described in (a) above, whether directly or indirectly;
• (c) a resident, national, or citizen of, or an entity organised under the laws of, any country subject to comprehensive sectoral, financial, or trade sanctions.

Due to the severity and breadth of applicable sanctions, the Platform applies the following enhanced measures regarding Russia:

• No Russian Exchangers — The Platform will not list any exchanger incorporated, registered, or operating in the Russian Federation, or owned/controlled by Russian nationals or entities;
• No Russian Payment Systems — Exchangers facilitating transactions involving Russian Ruble (RUB) or Russian payment systems (including MIR cards) are prohibited;
• Anti-Circumvention — The Platform actively prevents use of intermediary jurisdictions, shell entities, or nominee arrangements to evade Russian sanctions;
• User Representation: By accessing the Platform, users confirm they are not located in Russia, do not act on behalf of Russian persons or entities, and will not use the Platform to circumvent Russian sanctions.

Access is prohibited for:

• Individuals or entities listed on:
  • the UK Sanctions List;
  • UN Consolidated Sanctions List;
  • EU Consolidated List of Sanctioned Persons;
  • OFAC Specially Designated Nationals (SDN) List;
• Entities 50% or more owned/controlled by designated persons;
• Persons acting on behalf of, for the benefit of, or at the direction of sanctioned individuals or entities.

(a) FATF Call for Action ("Blacklist"). In accordance with the FATF Recommendations and applicable BVI AML/CFT legislation, each as amended from time to time, the Company will not knowingly list or interact with Listed Exchangers or Users principally operating in a jurisdiction designated by the FATF as a High-Risk Jurisdiction Subject to a Call for Action, as such designation is updated from time to time and published on the official FATF website.

(b) FATF Jurisdictions under Increased Monitoring ("Grey List"). The Company applies enhanced due diligence with respect to Listed Exchangers and, to the extent information is available to it, with respect to Users, in connection with any jurisdiction designated by the FATF as being under Increased Monitoring, as such designation is updated from time to time and published on the official FATF website. Users acknowledge that the jurisdiction of the Company's incorporation may from time to time be so designated, and that the Company maintains AML/CFT controls calibrated accordingly.

(c) Updates. The Company monitors FATF publications on an ongoing basis and updates its internal compliance policies and risk assessments in line with any change to the designations referred to in this Section 6.

The Company remains subject to an absolute obligation not to deal with any sanctioned person or Prohibited Jurisdiction, as required under UK sanctions legislation extended to the BVI and BVI AML/CFT obligations. To support compliance with this obligation, the Platform may employ, at its discretion and where technically feasible, controls including:

• IP Address Screening — the Platform may screen and, where reasonably practicable, block access attempts from IP addresses geolocated to Prohibited Jurisdictions;
• Sanctions List Screening — the Platform may screen Listed Exchangers against applicable sanctions databases prior to listing and on an ongoing basis;
• User Access Monitoring — the Platform reserves the right to collect and analyse geolocation data, IP addresses, and device information to assist in verifying compliance with territorial restrictions;
• Immediate Suspension — The Platform may immediately suspend, remove, or block any exchanger or user where reasonable grounds exist to believe a connection to a Prohibited Jurisdiction or sanctioned person.

No such technical control constitutes a guarantee of detection, and the Company does not warrant that these measures will identify every attempt to access the Platform from a Prohibited Jurisdiction or by a sanctioned person, including where such attempts involve circumvention technologies (e.g. VPNs or proxy services).

Data Processing: Where geolocation, IP address, or device data is processed under this Section, it is processed solely for the purpose of supporting sanctions compliance, as required under UK sanctions legislation extended to the BVI and BVI AML/CFT obligations.

All exchangers undergo sanctions screening before and during their listing on the Platform.

The Platform reserves the right to report suspected sanctions breaches or suspicious activity to:

• BVI Governor's Office;
• BVI Financial Services Commission (FSC);
• BVI Financial Investigation Agency (FIA);
• UK Office of Financial Sanctions Implementation (OFSI);
• Other competent authorities as required by law.

The Platform accepts no liability for any loss, damage, or inconvenience arising from sanctions compliance actions, including refusal to list, suspension, removal, or blocking of access. Compliance with applicable sanctions laws takes unconditional precedence over any commercial arrangement.

To access the Platform, users must confirm they:

• Are not residents, nationals, or citizens of a Prohibited Jurisdiction;
• Are not listed on any sanctions list maintained by any Sanctions Authority;
• Are not acting on behalf of any sanctioned person or entity;
• Will use the Platform in compliance with all applicable laws in their jurisdiction.

Failure to meet these conditions requires immediate cessation of Platform use.

This Policy is subject to change as international sanctions frameworks evolve. The Platform monitors:

• UK, UN, EU, and US sanctions updates;
• FATF plenary updates;
• BVI regulatory guidance from the FSC and FIA;
• Legislative developments in other relevant jurisdictions.

Users are responsible for reviewing this Policy and the Platform's Terms of Use regularly.

In the event of any conflict between this Policy and the Terms of Use, the Terms of Use shall prevail.

For any questions, concerns or other enquiries regarding this Policy, please contact: