# Geoblocking Policy

#### 1. Purpose and general rule

AlphaYields restricts access to the Services whenever necessary for compliance with restrictive
\
measures/sanctions, legal obligations and internal risk management policy. It is prohibited to use the
\
Services where the User is located, habitually resides, or acts on behalf of or for the benefit of persons
 or entities in prohibited jurisdictions or those subject to sanctions.

{% hint style="info" %}
*Legal references: EU sanctions (CFSP Decisions/Council Regulations); GDPR, Article 6(1)(c) and (f)*
\
*(compliance/security, where applicable); Regulation (EU) 2018/302 (geoblocking – restriction for legal compliance);
 Law No. 83/2017 (AML/CTF, where applicable).*
{% endhint %}

#### 2. Technical measures and prevention of circumvention

AlphaYields may block IP addresses, detect VPN/proxy/Tor use, limit functionalities and request
\
additional declarations or information. It is prohibited to circumvent such measures or to use the
\
Services through intermediary persons.

{% hint style="info" %}
Legal references: EU sanctions; Civil Code, Article 762 (good faith); Decree-Law No. 7/2004 (security and
 prevention of abuse); GDPR, Article 32 (security).
{% endhint %}

#### 3. List of prohibited jurisdictions (hard block)

It is recommended to block, as a baseline: Cuba, Iran, North Korea, Syria, Russia, and the regions of
\
Crimea, Donetsk and Luhansk.

{% hint style="info" %}
Legal references: applicable sanctions/restrictive measures; risk management and compliance.
{% endhint %}

#### 4. High-risk jurisdictions (conditional block / EDD)

AlphaYields may restrict or condition access in jurisdictions classified as high-risk or monitored (e.g.
\
FATF lists), imposing enhanced due diligence where applicable to the operational model.

{% hint style="info" %}
Legal references: Law No. 83/2017 (risk-based approach; enhanced due diligence, where applicable); EU
 sanctions; GDPR, Article 6.
{% endhint %}

#### 5. Updates to the list

The list of jurisdictions may be updated without notice, depending on legal changes, sanctions regimes
 and risk assessment.

{% hint style="info" %}
Legal references: compliance with legal obligations and duty of diligence; GDPR, Article 5(2) (accountability, where
 applicable).
{% endhint %}


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