Prohibitions

Last Updated: 25 October 2025

Last updated: September 7, 2025

Use of the XPlace Card (as defined in the XPlace Card Terms for US and International users) for any dealings, engagement, or sale of goods/services linked directly or indirectly with jurisdictions that Pontech Group L.L.C-FZ. has deemed high risk, such as Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk Regions, or persons Pontech Group L.L.C-FZ has deemed high risk, such as those individuals or entities named to a restricted person or party list of the U.S., United Kingdom, European Union or United Nations, including the sanctions lists maintained by the U.S. Department of Treasury’s Office of Foreign Assets Control or the Denied Persons List or Entity List maintained by the U.S. Department of Commerce, is prohibited

In addition to these exclusions from the XPlace platform, Pontech Group L.L.C-FZ does not allow companies registered in prohibited jurisdictions, or individuals from prohibited jurisdictions to open accounts. The list of currently prohibited jurisdictions is as follows and may be updated from time to time as required by relevant authorities or changes in applicable laws, or at Pontech Group L.L.C-FZ's discretion.

Restricted Jurisdictions

XPlace accounts are not available in the following countries (this list may be updated at any time):

• Afghanistan

• Albania

• Belarus

• Bosnia

• Central African Republic

• Congo

• Croatia

• Cuba

• Cyprus

• Eritrea

• Haiti

• Iran

• Iraq

• Kosovo

• Lebanon

• Liberia

• Libya

• Macedonia

• Moldova

• Montenegro

• North Korea

• Russia

• Serbia

• Somalia

• Syria

• Ukraine

• Venezuela

• Vietnam

• Yemen

• Zimbabwe

Prohibited Activities

1. Regulated or Illegal

• Sale of narcotics and controlled substances without proper licensing

• Manufacturing or selling weapons, ammunition, or explosives

• Pornography (including child pornography)

• Gambling, lotteries, and betting services

• Prostitution and escort services

• Sale of counterfeit goods

• Ponzi schemes or pyramid schemes

2. Intellectual Property Infringement

• Distribution of unlicensed software, music, or films

• Sale of counterfeit goods

• Unlawful import/export of protected items

3. Violence and Hate

• Promotion of violence, extremism, or hate speech

• Discrimination based on race, religion, gender, or nationality

4. Misuse of Pontech Group L.L.C-FZ Products

• Providing falsified information during account creation

• Conducting transactions on behalf of third parties without disclosure

• Using XPlace trademarks or brand assets without written consent

5. Restricted Activities (subject to enhanced due diligence and potential restrictions)

• Financial institutions (banks, brokers, investment funds, asset managers)

• Sale of certain pharmaceutical products (licensed only)