Sanctions and Other Restrictions

1. Sanctions

We are committed to upholding global regulatory standards, particularly in adhering to economic sanctions and restrictive measures targeting certain government officials and other persons and entities, including those implemented from time to time by:

• the Office of Foreign Assets Control ("OFAC") within the U.S. Department of the Treasury;

• the United Nations pursuant to any United Nations Security Council Resolution;

• any European Union Council or Commission Regulation or Decision adopted pursuant to a Common Position in furtherance of the European Union's Common Foreign and Security Policy;

• the United Kingdom, imposed from time to time by HM Treasury in the United Kingdom of Britain and Northern Ireland and/or the Bank of England

Regardless of your geographical location, our sanctions policy applies universally to all members. When creating or updating your account it is essential to provide accurate information about yourself and your country of residence. Failure to do so may lead to the termination of your account or page.

In accordance with our commitment to compliance, we observe restrictions on transactions involving:

• Certain countries, including Cuba, Iran, North Korea, Syria, and specific regions such as Crimea, the Donetsk People’s Republic (DNR), and Luhansk People’s Republic (LNR), along with any individuals or entities operating or residing therein

• Individuals or entities listed on sanctions rosters, such as OFAC’s Specially Designated Nationals (“SDN”) List or the Foreign Sanctions Evaders (“FSE”) List

To safeguard our community and ensure adherence to these regulations, we undertake various measures, including:

• Prohibiting access from certain geographic locations

• Restricting creators from offering benefits originating from sanctioned areas

• Requesting additional information or actions from users to facilitate compliance

Should we suspect any violation of economic sanctions or trade restrictions, including operating an account from a sanctioned location or benefiting sanctioned entities, we reserve the right to suspend, terminate, or take appropriate action on the account.

Furthermore, it is important to note that different countries may impose additional trade restrictions, and certain items may be subject to export or import prohibitions under international laws. Members engaging in transactions with international parties should familiarize themselves with relevant jurisdictional laws. For legal counsel, consulting a qualified professional is recommended.

Additionally, our payment partners, such as PayPal, Visa, and Mastercard, independently monitor financial transactions for sanctions compliance and may block transactions as part of their own compliance protocols. Please be aware that we do not influence or control the decisions made by these providers.

Given the dynamic nature of economic sanctions and trade restrictions, updates may occur frequently, potentially impacting our ability to engage with members or imposing additional restrictions on benefits. We encourage members to stay informed by referring to relevant resources provided by authoritative bodies, including the US Department of the Treasury, Bureau of Industry and Security at the US Department of Commerce, Department of State, and the European Commission.

1. Political Exposes Persons

A politically exposed person (“PEP”) is an individual who is or has been entrusted with a prominent function by a local, regional, national or international governmental body.

Because of the risks associated with PEPs, the FATF Recommendations require the application of additional AML/CFT measures to business relationships with PEPs. These requirements are preventive (not criminal) in nature, and should not be interpreted as meaning that all PEPs are involved in criminal activity, or even necessarily pose a high risk of money laundering. Further legislation around the world, including the EU’s 4th money laundering directive, mandates enhanced due diligence requirements when dealing with all politically exposed persons.

Due to the above we do not provide services to PEPs. Should we suspect operating an account by a PEP at a sanctioned location or for the benefit of a PEP we reserve the right to suspend, terminate, or take appropriate action on the account.

1. Other Restrictions

3.1. Undesirable organizations in Russia

According to Russian law, organizations designated as “undesirable” are prohibited from conducting any activities within the Russian Federation. Once classified as undesirable, such entities are blocked from operating or maintaining a domestic presence in any form, including undertaking financial transactions.

Financing an undesirable organization is illegal under the Criminal Code of the Russian Federation. We therefore do not provide services to organizations designated as “undesirable” in Russia and reserve the right to suspend, terminate, or take appropriate action on the account if we suspect operating an account by an “undesirable” organization.

3.2. Persons listed as extremists and terrorists in Russia

Providing or collecting funds, or rendering financial services knowingly intended for financing extremist crimes or activities leads to criminal liability under the Criminal Code of the Russian Federation. Therefore, any transfer of funds or digital assets to creators designated as an extremist or a terrorist poses risks to us and reserve the right to suspend, terminate, or take appropriate action on the account of we suspect operating an account by a person listed as an extremist or a terrorist in Russia.