--- title: Restricted persons draft description: The launch restricted list and draft eligibility provisions for trading and pool notes. --- Version: draft-2026-11-14-3. Dated: 2026-11-14. Effective date: **[OWNER AND COUNSEL TO COMPLETE]**. Mainnet is not open. This draft records the settled launch restricted list for review and devnet testing. Publishing it does not deploy the eligibility checks or open a product in any place. ## Launch country schedule The launch policy refuses new positions and new liquidity deposits from people located in or resident in the following places. Pool notes use at least the same restrictions as trading; separate legal review may require more restrictions on notes. - United States and Canada - The European Union countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden - Iceland, Liechtenstein and Norway - United Kingdom, Singapore, Australia, Hong Kong, Japan, South Korea, Brazil and United Arab Emirates This is the settled launch country list for both products. Omission from the list does not establish that a product is lawful or available there. Commercial restrictions and sanctions are different grounds for refusal. The launch sanctions geography additionally excludes Cuba, Iran, North Korea and Ukraine's Crimea, Donetsk, Luhansk and Sevastopol. Location checks exclude each of those Ukrainian subdivisions as a whole. This is a distribution rule, not a claim that every part of a subdivision has the same legal status. ## People, entities and ownership The draft location and residence rule is broader than a check of the current network address. Citizenship, tax residence, entity organisation, registered office, controlling owners and persons acting for another may also affect eligibility. The final definitions and any citizenship or ownership thresholds are **[OWNER AND COUNSEL TO COMPLETE]**. This draft does not invent them or reduce a person test to an IP check. You must have legal capacity and authority to act, give accurate information and update it when circumstances change. Do not act for a person whose use would be prohibited. A transferable note can reach a restricted wallet outside our services. A token transfer does not remove the recipient's restrictions or establish a right to use team services. ## Sanctions and continuing checks You must not use the services for a transaction prohibited by sanctions that apply to you, the operator or the transaction. This includes restrictions arising from designation or applicable ownership and control rules, even when a wallet address is absent from a published list. Exact applicable laws, lists and ownership definitions need the named operator and counsel's review: **[OWNER AND COUNSEL TO COMPLETE]**. The launch policy also refuses OFAC-listed Solana wallets, using the US Treasury's published designated Solana addresses. This planned check does not prove a person is eligible or that a transaction is lawful when an address has no match. Lists can change, lookups can fail and indirect ownership can be missed. This document does not claim that screening checks every relevant person or law. The proposed policy allows information requests and review, refusal of new risk, and holds, rejection or reporting where law requires them. Final decision authority, information requirements and review contact: **[OWNER AND COUNSEL TO COMPLETE]**. Any report or disclosure must follow applicable law and the privacy notice. ## Concealment and errors Do not use a VPN, proxy, false statement, another person's wallet or any other method to hide ineligibility or evade a restriction. An incorrect network location can also block an eligible person. A failed or uncertain check is not evidence of wrongdoing, and a successful check does not establish nationality or residence. The proposed policy refuses new risk while eligibility is unresolved and offers a review of errors through a contact still **[OWNER AND COUNSEL TO COMPLETE]**. The complete review procedure and response time are not established. Review can correct a factual mistake; it cannot permit a transaction that the law prohibits. ## Existing positions and notes For an ordinary country restriction alone, the intended service policy preserves lawful cash-out, settlement and note withdrawal. Those actions still depend on the program's rules, services, pool funds and any applicable emergency pause or freeze. Country restrictions do not promise immediate payment. Sanctions need separate review and may prevent payment or withdrawal. The final lawful-offboarding process and authority to impose or release a hold remain **[OWNER AND COUNSEL TO COMPLETE]**. This draft gives no assurance that the team can stop every direct on-chain action or that funds can always leave. Read this schedule with the [terms](/docs/legal/terms-2026-11-14-3), [risk schedule](/docs/legal/risks-2026-11-14-3) and [privacy notice](/docs/legal/privacy-2026-11-14-3). A future change needs a new dated version and clear notice. These pages do not themselves turn on eligibility checks or record your acceptance.