Restricted & Prohibited Jurisdictions Policy

This Policy identifies jurisdictions in which DaisyLink Financial Ltd (“DaisyLink”) is prohibited from, or must apply enhanced controls before, onboarding customers, processing transactions, or otherwise conducting business. It supports DaisyLink’s obligations as a Bank of Canada RPAA-registered payment service provider and a FINTRAC-registered money services business with virtual currency permissions, and is intended to be read together with DaisyLink’s AML/KYC Compliance Program, Operational Risk Management Framework, and Schedule 4 (Sanctions Jurisdictions) of the Client Application Terms.

The restrictions set out in this Policy derive from the following legal sources, not from Bank of Canada RPAA supervision:

• Special Economic Measures Act (SEMA) — Canada’s primary autonomous sanctions statute, administered by Global Affairs Canada, authorizing country-specific sanctions regulations.
• United Nations Act (UNA) — implements UN Security Council sanctions resolutions into Canadian law.
• Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) — targeted sanctions against corrupt foreign officials.
• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC guidance — requires enhanced due diligence for higher-risk jurisdictions, informed by FATF’s public statements.
• FATF (Financial Action Task Force) — publishes the “High-Risk Jurisdictions subject to a Call for Action” (blacklist) and “Jurisdictions under Increased Monitoring” (grey list), updated three times yearly (February, June, October Plenaries).
• U.S. OFAC sanctions — relevant to DaisyLink’s USD-referenced stablecoin (USDT) activity, given USDT’s issuer’s own OFAC compliance obligations and potential USD correspondent banking exposure.

DaisyLink must not onboard customers resident in, or knowingly process transactions involving, the following jurisdictions, consistent with FATF’s Call for Action and Canada’s most severe sanctions regimes:

In addition, the following jurisdictions are subject to comprehensive Canadian sanctions (SEMA) and are treated as prohibited for onboarding and transaction purposes:

• Belarus — comprehensive sectoral and financial sanctions under SEMA.
• Russia — comprehensive sanctions under SEMA, including the Crimea, Donetsk, and Luhansk regions of Ukraine.

The following jurisdictions are subject to targeted (rather than comprehensive) Canadian sanctions. DaisyLink may only deal with counterparties in these jurisdictions after confirming they are not designated persons or entities on the Consolidated Canadian Autonomous Sanctions List, and subject to enhanced due diligence. Iran, Myanmar, and North Korea are excluded from this table as they are already comprehensively prohibited under Section 3 above.

Grey-listed jurisdictions are not subject to a Canadian legal prohibition, but FATF guidance calls for a risk-based approach and correspondent banks routinely apply enhanced due diligence. DaisyLink should apply enhanced due diligence (source of funds verification, senior management sign-off, increased transaction monitoring) to customers connected with the following jurisdictions, current as of the June 2026 FATF Plenary:

Given DaisyLink’s virtual currency permissions, the restrictions above apply equally to: customer residency and IP/geolocation at onboarding; the jurisdiction of counterparty wallets and virtual asset service providers (VASPs) in transaction flows; and beneficial ownership of corporate customers. Blockchain analytics screening should be applied to wallet addresses to detect exposure to sanctioned jurisdictions, consistent with DaisyLink’s existing no-refunds and sanctions clauses in the Client Application Terms and Schedule 4.

This Policy must be reviewed and updated:

• Within 30 days of each FATF Plenary announcement (scheduled for February, June, and October each year);
• Immediately upon any amendment to the Consolidated Canadian Autonomous Sanctions List or new SEMA/UNA regulations affecting a jurisdiction;
• At least annually as part of DaisyLink’s broader AML/CFT risk assessment;
• Upon any material change to DaisyLink’s product offering (e.g., new fiat corridors, new stablecoins) that changes exposure to foreign sanctions regimes such as OFAC’s.

The DaisyLink Compliance Officer / MLRO is responsible for maintaining this Policy, escalating jurisdiction changes to senior management, and ensuring onboarding and transaction monitoring systems reflect the current lists.

This document has been prepared for internal planning purposes based on publicly available sanctions and FATF information as of July 6, 2026. Sanctions lists and FATF classifications change frequently and without notice. Before relying on this Policy operationally, DaisyLink must verify current status directly against the Global Affairs Canada Consolidated Canadian Autonomous Sanctions List, the FATF’s published lists at fatf-gafi.org, the OFAC Specially Designated Nationals (SDN) List, and should obtain sign-off from qualified legal/compliance counsel. This document does not constitute legal advice.