Geographical and Investor Restrictions

A. Global Restrictions (Applicable to All Products)

  1. Restricted Jurisdictions: Services are not provided to countries/regions under comprehensive sanctions/embargoes (e.g., Cuba, Iran, North Korea, Syria, and Crimea/Donetsk/Luhansk regions of Ukraine). The strictest applicable regulatory list shall prevail in case of changes.

  2. Restricted Entities: Individuals or entities listed on sanctions lists (UN/EU/UK/US, including SDN), export control, or anti-terrorism lists are prohibited from participation.

  3. Circumvention and Anonymity: Use of VPNs, proxies, or anonymizing tools to bypass geoblocking or KYC/AML controls is prohibited. Upon detection, the platform may refuse, freeze, or revoke transactions and access.

B. Jurisdiction-Specific General Restrictions

  • United States: Except under exemptions, unregistered securities may not be offered or sold within the U.S. or to “U.S. persons” (Reg S); secondary resale is restricted.

  • EU/EEA: Offerings/sales only to qualified investors (Prospectus Regulation); retail investors are not the target market; distribution complies with MiFID II, etc.

  • United Kingdom: Promotion only to professional clients and specified licensed persons; general retail solicitation is prohibited.

  • Switzerland: Available only to professional clients/qualified investors; no public offering.

  • Singapore: Targeted at institutional/accredited investors; no retail distribution.

  • Hong Kong: Distributed only to professional investors; not considered a public offer.

  • Australia: Offered only to wholesale/professional clients; no retail offering.

  • Canada: Distributed under exemption frameworks to qualified/licensed investors; provincial secondary resale restrictions apply.

  • Japan/Mainland China: Offers or sales to local residents are prohibited without required registration or exemptions.

C. Eligibility and Transfer Controls

  • Participation limited to professional/qualified investors; completion of KYC/AML, suitability assessment, and jurisdictional compliance required.

  • Pre-transfer checks on eligibility, jurisdiction, limits, and holder type before secondary circulation; non-compliant instructions will be automatically rejected or reverted.

  • In case of conflicting or updated jurisdictional rules, the stricter rule applies; the platform dynamically adjusts serviceable regions and restriction lists.

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