List of Prohibited Countries and Restricted Persons

Updates & Sources

We regularly update this Policy and screen against official consolidated sources (EU Sanctions Map, OFAC SDN, UK HMT, Canada Sanctions List, DFAT).

Introduction

Cwallet may not make all of the Services available in all markets and jurisdictions, and may restrict or prohibit the use of Services.This Policy implements EU, UN, and Slovak sanctions and AML obligations, including Act No.289/2016 Coll (international sanctions) and Act No.297/2008 Coll. (AML), as well as relevant EU restrictive measures and partner jurisdictions’ lists (OFAC, UK HMT, Canada, Australia (DFAT).The below countries, and locations, as designated by Cwallet, form the List of Prohibited Countries as described in Cwallet's Terms of Service. Cwallet reserves the right to update the list at its discretion without prior notice.

Definitions

"Restricted Persons" means any individual or entity listed on or owned/controlled (≥50%) by a person or entity on the above sanctions lists or otherwise targeted by EU/UN/US/UK/CA/AU restrictive measures. Also includes any legal person or entity whose beneficial owner(s) is/are listed or targeted by EU, UN or other international sanctions."Prohibited Countries" include (non-exhaustive): Afghanistan, Belarus, Cuba, Iran, North Korea (DPRK), Russia, Russian-controlled regions of Ukraine, Sudan, as well as any other jurisdiction subject to comprehensive international sanctions or where providing services would breach applicable law.

Prohibited Countries

In order to be eligible for a Cwallet Account and use the Services, you must not be:a.) located, incorporated, otherwise established in, a resident of, a citizen of, or operating in:AfghanistanCubaChinese MainlandGuinea-BissauHaitiIranIraqLebanonLibyaMyanmarNorth KoreaPakistanRussiaRussian-controlled regions of Ukraine (including the Crimea, Donetsk, and Luhansk regions)SomaliaSudanThe Central African RepublicThe Democratic Republic of the CongoVenezuelaYemenZimbabweAs well as any other jurisdiction subject to comprehensive international sanctions or where providing services would breach applicable law.Access is also prohibited for persons from FATF "High-Risk" jurisdictions, unless and until removed from such lists.In accordance with MiCA Article 63(6)(b) and Directive (EU) 2015/849 Article 9, Amarium s.r.o. shall apply enhanced due diligence to any business relationship involving a person resident in or transactions linked to a high-risk third country as identified by the European Commission.

Sanctions Lists

b.) on any trade or economic sanctions lists such as:The Office of Foreign Assets Control (“OFAC”) specially designated national (“SDN”) listsThe denied persons or entity list of the U.S. Department of CommerceAny regions or countries which the EEA has imposed applicable restrictions or sanctions on (EU sanction list)The UK Sanctions ListThe Canada Sanctions ListThe official DFAT sanctions list (Australia)The United Nations Security Council Sanctions List*Sanctions screening covers UN, EU, OFAC, UK HMT, Canada, and Australia (DFAT Consolidated List)In line with Act No. 297/2008 Coll. Article 20a(4–5), Amarium s.r.o. shall apply enhanced AML controls to transfers involving self-hosted crypto addresses, obtaining information on originator/destination and assessing the risk of sanctions evasion.

Screening & Escalation

Potential matches trigger enhanced due diligence and manual compliance review. Confirmed matches result in suspension and reporting to authorities under Act 297/2008 Coll.The internal procedures shall ensure compliance with Directive (EU) 2015/849 Article 18a: all crypto-asset transfer orders will include complete originator and beneficiary information, and any missing or incomplete information will be reported or blocked according to national law.All staff involved in compliance and transaction monitoring will receive AML/CFT training at least annually, including updates on sanctions lists and restricted jurisdictions, in accordance with Act No. 297/2008 Coll. Article 13(3).

Enforcement & Contractual Link

Any assets or crypto held for a ‘Restricted Person’ shall be frozen and not transferred or withdrawn, and Amarium s.r.o. will notify the competent authority promptly, in compliance with Act No. 289/2016 Coll. On international sanctions and relevant EU/UN sanctions regulations.Violation of this Policy constitutes a material breach of our Terms of Service and may result in immediate termination or asset freeze as required by law.

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Effective Date: 20 October 2025. Version: I