# 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.