🚷Prohibited Persons Policy

DXS BROKERAGE LLC PROHIBITED PERSONS POLICY; Last updated May 08, 2025

1. POLICY OVERVIEW

1.1 Purpose This Prohibited Persons Policy ("Policy") establishes the framework for identifying and restricting access to DXS Brokerage LLC's services ("DXS" or "Service") by individuals and entities from certain jurisdictions or who meet specific prohibited criteria. This Policy is designed to ensure compliance with international sanctions, anti-money laundering regulations, and applicable financial services laws.

1.2 Scope This Policy applies to all DXS services, including but not limited to: • Account opening and maintenance • Trading and investment services • Digital asset transactions • Financial product offerings • Customer onboarding and due diligence processes

1.3 Legal Framework This Policy is established in compliance with: • Office of Foreign Assets Control (OFAC) sanctions • European Union sanctions and regulations • United Nations sanctions • Financial Action Task Force (FATF) recommendations • Saint Vincent and the Grenadines regulatory requirements • Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) laws

1. PROHIBITED PERSONS DEFINITION

You may not access, use, or engage in any transaction on DXS if you are a Prohibited Person. A "Prohibited Person" includes any individual or entity who:

2.1 Geographic Restrictions Is a citizen, resident, or domiciled in any Prohibited Jurisdiction as defined in Section 3 of this Policy.

2.2 Sanctions-Based Restrictions Is a Sanctioned Person as defined in Section 4 of this Policy.

2.3 Ownership and Control Restrictions • Is directly or indirectly owned, controlled by, or acting on behalf of a Prohibited Person • Holds 50% or more ownership interest in an entity that is a Prohibited Person • Has authority to control substantial decisions of an entity that is a Prohibited Person.

2.4 Regulatory Restrictions Is subject to licensing, accreditation, or regulatory requirements that DXS cannot satisfy in the relevant jurisdiction.

1. PROHIBITED JURISDICTIONS

3.1 Sanctions-Based Prohibited Jurisdictions The following countries and territories are prohibited due to international sanctions imposed by the United States, European Union, United Nations, or other relevant authorities:

3.1.1 Comprehensive Sanctions Countries • Afghanistan (Taliban-controlled areas) • Belarus • Cuba • Iran (Islamic Republic of Iran) • Myanmar (Burma) • North Korea (Democratic People's Republic of Korea) • Russia (Russian Federation) • Syria (Syrian Arab Republic)

3.1.2 Regional Sanctions Areas • Crimea • Donetsk • Luhansk

3.1.3 Targeted Sanctions Countries Countries subject to sectoral or targeted sanctions that affect financial services: • Central African Republic • Democratic Republic of Congo • Guinea • Guinea-Bissau • Haiti • Iraq (certain sectors and entities) • Lebanon (banking sector restrictions) • Libya • Mali • Nicaragua • Somalia • South Sudan • Sudan • Venezuela (Bolivarian Republic of Venezuela) • Yemen • Zimbabwe

3.1.4 Additional High-Risk Jurisdictions Countries identified by FATF or other authorities as high-risk for money laundering or terrorism financing: • Burundi • Eritrea

3.2 Regulatory-Based Prohibited Jurisdictions The following jurisdictions are prohibited due to regulatory requirements that DXS cannot satisfy:

3.2.1 European Union Member States DXS cannot provide services to residents of EU Member States due to MiFID II third-country regulatory requirements and the absence of EU equivalence determination for Saint Vincent and the Grenadines:

• Austria • Belgium • Bulgaria • Croatia • Cyprus • Czech Republic • Denmark • Estonia • Finland • France • Germany • Greece • Hungary • Ireland • Italy • Latvia • Lithuania • Luxembourg • Malta • Netherlands • Poland • Portugal • Romania • Slovakia • Slovenia • Spain • Sweden

3.2.2 Other Regulatory Restricted Jurisdictions • United States of America (including all states, territories, and possessions) • Canada • United Kingdom • Switzerland • Seychelles • Algeria • Ecuador • Qatar • Thailand • Israel • UAE • China • Taiwan • Singapore • Indonesia

3.2.3 Caribbean Jurisdictions with Regulatory Conflicts • Saint Vincent and the Grenadines • Anguilla • Antigua and Barbuda • Dominica • Grenada • Montserrat • Saint Kitts and Nevis • Saint Lucia

3.2.4 U.S. Territories and Dependencies • American Samoa • United States Minor Outlying Islands • Guam • Northern Mariana Islands • Puerto Rico • U.S. Virgin Islands

1. SANCTIONED PERSONS

4.1 Definition A "Sanctioned Person" refers to any person, entity, or digital asset address that is:

1. Specifically Listed: Named on any Sanctions List as defined in Section 5.7

2. Owned or Controlled: Directly or indirectly owned 50% or more by any individual or entity listed on a Sanctions List

3. Government Officials: Government officials or representatives of any Prohibited Jurisdiction

4. Associated Entities: Entities acting on behalf of or at the direction of a Sanctioned Person

4.2 Sanctions Lists Monitoring DXS maintains ongoing monitoring of all relevant sanctions lists and updates screening procedures accordingly.

1. KEY DEFINITIONS

5.1 "U.S. Person" Means any of the following:

1. A U.S. citizen or resident (including green card holders)

2. A corporation, partnership, or other entity established or organized in or under the laws of the United States

3. Any estate of a decedent who was a citizen or resident of the United States

4. Any trust if: • A court within the United States can exercise primary supervision over the trust administration, AND • One or more U.S. Persons have authority to control all substantial decisions of the trust

5. Any entity organized outside the United States where U.S. Persons: • Hold 50% or greater equity interest by votes or value, OR • Hold a majority of board seats or memberships, OR • Control actions, policies, personnel decisions, or day-to-day operations

6. Any pension plan for employees, officers, or principals of a U.S. entity (unless primarily for foreign employees)

5.2 "Prohibited Jurisdiction" Any country, territory, or region listed in Section 3 of this Policy, including but not limited to areas subject to comprehensive sanctions, targeted sanctions, or regulatory restrictions that prevent DXS from providing compliant services.

5.3 "Citizen" A person who holds citizenship or nationality of a country, regardless of residence or domicile.

5.4 "Resident" A person who: • Maintains primary residence in a jurisdiction • Has legal resident status in a jurisdiction • Spends more than 183 days per year in a jurisdiction • Has significant economic or personal ties to a jurisdiction

5.5 "Domiciled" A person whose permanent home or principal establishment is in a particular jurisdiction for legal purposes.

5.6 "Entity" Includes corporations, partnerships, limited liability companies, trusts, foundations, associations, and any other legal or commercial structure.

5.7 "Sanctions List" Includes but is not limited to: • OFAC Lists: Specially Designated Nationals (SDN) List, Sectoral Sanctions Identifications List, and other OFAC-administered lists • EU Sanctions Lists: European Union consolidated sanctions list • UN Sanctions Lists: United Nations Security Council sanctions lists • FATF Lists: Financial Action Task Force high-risk and non-cooperative jurisdictions • National Lists: Sanctions lists maintained by the United Kingdom, Canada, Australia, and other relevant jurisdictions • Other Lists: Any terrorist organization, sanctioned, restricted, or debarred party lists published by relevant authorities

5.8 "Digital Asset Address" Any blockchain address, wallet address, or other identifier associated with digital assets or cryptocurrency transactions.

1. PROHIBITED ACTIVITIES

6.1 Account Restrictions Prohibited Persons may not: • Open or maintain accounts with DXS • Access DXS trading platforms or services • Hold, own, or operate wallets on DXS services • Execute transactions or place orders through DXS

6.2 Third-Party Restrictions No person may: • Operate accounts or execute transactions for the benefit of Prohibited Persons • Act as intermediary or agent for Prohibited Persons • Facilitate access to DXS services by Prohibited Persons • Transfer funds or assets to or from Prohibited Persons through DXS

6.3 Circumvention Prohibited Any attempt to circumvent these restrictions is strictly prohibited, including: • Using false identity information • Using VPNs or other tools to mask location • Using intermediaries to access services • Creating multiple accounts to evade restrictions

1. COMPLIANCE PROCEDURES

7.1 Customer Due Diligence DXS implements comprehensive customer due diligence procedures including: • Identity verification and documentation • Address verification and proof of residence • Sanctions list screening at onboarding and ongoing • Enhanced due diligence for high-risk customers • Ongoing monitoring of customer activities

7.2 Screening Requirements All customers and transactions are screened against: • Current sanctions lists (updated daily) • Prohibited jurisdictions list • High-risk country indicators • Politically Exposed Persons (PEP) databases • Adverse media and law enforcement databases

7.3 Geographic Verification DXS employs multiple methods to verify customer location: • IP address analysis and geolocation • Document verification and address confirmation • Phone number verification • Payment method verification • Ongoing transaction monitoring for location indicators

7.4 Ongoing Monitoring DXS maintains continuous monitoring including: • Regular re-screening against updated sanctions lists • Transaction pattern analysis • Location verification monitoring • Periodic customer information updates • Suspicious activity monitoring and reporting

1. ENFORCEMENT AND REMEDIAL ACTIONS

8.1 Account Restrictions Upon identification of a Prohibited Person, DXS will: • Immediately suspend account access • Freeze all assets and transactions • Conduct investigation and documentation • Report to relevant authorities as required • Implement permanent account closure if confirmed

8.2 Asset Handling For accounts of confirmed Prohibited Persons: • Assets will be frozen pending regulatory guidance • Funds may be blocked or transferred to appropriate authorities • No withdrawals or transactions will be permitted • Legal counsel will be consulted for proper procedures

8.3 Reporting Requirements DXS will report Prohibited Person activities to: • Saint Vincent and the Grenadines Financial Intelligence Unit • Relevant sanctions authorities (OFAC, EU, UN) • Law enforcement agencies as appropriate • Regulatory authorities as required

1. CUSTOMER RESPONSIBILITIES

9.1 Disclosure Obligations Customers must: • Provide accurate and complete information • Immediately notify DXS of any changes in citizenship, residence, or domicile • Disclose any connections to Prohibited Jurisdictions or Sanctioned Persons • Comply with all applicable laws and regulations in their jurisdiction

9.2 Travel and Temporary Presence Customers traveling to or temporarily present in Prohibited Jurisdictions: • Must not access DXS services while in such jurisdictions • Should notify DXS of extended stays in restricted areas • Acknowledge that services may be unavailable or blocked • Remain responsible for compliance with local laws

9.3 Legal Compliance Customers are responsible for: • Checking applicable laws in their jurisdiction • Ensuring compliance with local regulations • Understanding restrictions that may apply to their activities • Seeking legal advice when necessary

1. POLICY ADMINISTRATION

10.1 Review and Updates This Policy is reviewed and updated: • Quarterly for sanctions list changes • Annually for comprehensive policy review • Immediately upon significant regulatory changes • As required by legal or business developments

10.2 Approval Authority • Policy updates require approval by DXS Compliance Officer • Significant changes require Board of Directors approval • Emergency updates may be implemented with subsequent approval

10.3 Training and Communication • All staff receive regular training on this Policy • Updates are communicated to relevant personnel immediately • Customer notifications are provided for material changes

1. EXCEPTIONS AND WAIVERS

11.1 General Principle No exceptions or waivers to this Policy are permitted for: • Sanctions-based restrictions • Regulatory requirements that cannot be satisfied • Legal prohibitions under applicable law

11.2 Limited Exceptions In extraordinary circumstances, limited exceptions may be considered for: • Humanitarian purposes (subject to regulatory approval) • Legal obligations (with appropriate legal counsel) • Regulatory requirements (with authority approval)

11.3 Exception Process Any potential exception must: • Be approved by senior management and legal counsel • Receive regulatory approval where required • Be documented with full legal justification • Include ongoing monitoring and reporting requirements

1. CONTACT INFORMATION

12.1 Compliance Inquiries For questions regarding this Policy: Email: [email protected] Subject Line: Prohibited Persons Policy Inquiry

12.2 Reporting Violations To report potential violations: Email: [email protected] Subject Line: Policy Violation Report

12.3 Customer Support For general customer inquiries: Website: https://faq.dxs.app Email: [email protected]

1. LEGAL DISCLAIMERS

13.1 Policy Scope This Policy supplements but does not replace other DXS terms of service, privacy policies, or legal agreements.

13.2 Legal Advice This Policy does not constitute legal advice. Customers should consult qualified legal counsel regarding their specific circumstances.

13.3 Regulatory Changes DXS reserves the right to modify this Policy immediately to comply with changing legal or regulatory requirements.

13.4 Enforcement DXS reserves the right to enforce this Policy in its sole discretion and to take any actions necessary to ensure compliance.

This document contains confidential and proprietary information of DXS Brokerage LLC. Distribution is restricted to authorized personnel only.