Restricted Jurisdiction Policy

Last updated: October 7, 2025

By accessing or using Pingu.exchange or the Pingu Protocol, you confirm and agree that you are not:

• the target of any sanctions administered or enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United Nations Security Council, the European Union, Her Majesty’s Treasury / UK OFSI, or any other relevant legal or regulatory authority in any applicable jurisdiction;

• listed on the Specially Designated Nationals and Blocked Persons List (SDN List), the Consolidated Non-SDN Sanctions Lists, or any other sanctions lists maintained by OFAC or similar authorities;

• located, organized, or resident in, or otherwise subject to the jurisdiction of, any country or territory that is, or whose government is, the subject of comprehensive sanctions or restrictions, including but not limited to: United States (including its territories), Canada (Ontario), North Korea, Iran, Cuba, Syria, Russia, Belarus, and any other jurisdiction where the use of decentralized derivatives or similar products is prohibited by law;

• acting on behalf of, or for the benefit of, any person or entity described above.

Pingu.exchange may restrict or block access from restricted territories, including through IP-based controls or other geolocation measures. Attempts to circumvent such restrictions (for example, by using VPNs, proxies, or falsifying location or identity data) are strictly prohibited.

You are solely responsible for ensuring that your use of the Pingu Protocol and related Services is permitted under the laws and regulations applicable to you.