Export Control & Sanctions Policy

1. Purpose & Commitment

Nexa Group is committed to full compliance with all applicable export control and sanctions regulations, including but not limited to:

• U.S. Office of Foreign Assets Control (OFAC) Sanctions Programs
• U.S. Export Administration Regulations (EAR)
• EU Sanctions Regulations and EU Export Control Laws
• United Nations Security Council Sanctions & Embargoes
• UK Sanctions and Anti-Money Laundering Regulations
• Similar national regulations in countries where Nexa Group operates

These rules restrict certain users, entities, goods, software, and technologies from accessing Vexor services or monetization features. Violations may result in legal penalties, criminal liability, platform bans, and reporting to authorities.

2. Restricted Regions & Jurisdictions

Due to international sanctions, Vexor may restrict or block access — including account creation, payments, withdrawals, advertising, and monetization — for users located in or associated with the following categories:

• Countries under comprehensive OFAC sanctions (e.g., Cuba, Iran, North Korea, Syria)
• Regions sanctioned by the European Union
• Jurisdictions under UN trade embargoes or asset freeze programs
• Territories with prohibited export or re-export restrictions

Restrictions may also apply to individuals or organizations identified on sanctioned lists, regardless of geographic location.

3. Restricted Users & Entities

Vexor may block or limit services for the following categories of individuals and entities:

• Persons on OFAC’s Specially Designated Nationals (SDN) list
• Entities listed under EU Consolidated Financial Sanctions
• Individuals identified by UN terrorism sanctions lists
• Entities engaged in nuclear proliferation, weapons trafficking, or cyber-attacks
• Shell organizations associated with money laundering or fraud

4. Prohibited Uses of Vexor

Users may NOT use Vexor services for:

• Exporting technology to sanctioned territories or entities
• Transmitting software or data subject to export controls without authorization
• Supporting terrorist organizations, cybercrime networks, or illicit financing
• Distributing malware or cyber weapons
• Facilitating money laundering via digital currency transactions
• Circumventing sanctions through VPN masking, proxy routing, or identity manipulation

5. Screening & Compliance Checks

Vexor performs continuous sanctions compliance checks including:

• IP Geolocation Screening: Restricts access from sanctioned regions
• KYC Verification: Required for monetization and payouts
• Identity Screening: Matching against OFAC, EU, UN, and national lists
• Behavioral Monitoring: Detection of unusual financial or login activity
• Payment Provider Screening: Enforcement of PSP compliance rules

6. Payments, Payouts & Financial Restrictions

Vexor’s monetization and withdrawal features are subject to export and sanctions regulations. As such:

• Payouts cannot be sent to sanctioned individuals or bank accounts
• Virtual currency may not be purchased from prohibited jurisdictions
• Financial accounts may be frozen if sanctions violations are suspected
• Chargebacks involving restricted regions may trigger compliance reviews

7. Technology Export Considerations

Vexor’s software, algorithms, encryption technologies, and platform capabilities may be subject to export restrictions. Nexa Group ensures:

• Controlled technology is not transferred to restricted entities
• Server access is restricted by region when necessary
• Encrypted services comply with export regulations
• Engineering teams follow internal secure development policies

8. Detection, Investigation & Enforcement

If Vexor detects potential sanctions violations, the following actions may be taken:

• Immediate account suspension or monetization freeze
• Transaction reversal or cancellation
• Preservation of evidence for audit or regulatory purposes
• Reporting to relevant national or international authorities
• Permanent removal from the platform for repeated or intentional violations

9. Cooperation with Authorities

Nexa Group cooperates with legally valid requests from:

• OFAC and U.S. Treasury regulators
• EU Sanctions Compliance offices
• UN investigative bodies
• National security, customs, and export control authorities

All disclosures are made in accordance with our Privacy Policy and Law Enforcement Request Guide.

10. Employee Training & Internal Controls

Nexa Group maintains a formal compliance program that includes:

• Mandatory sanctions compliance training for relevant employees
• Internal monitoring and audit procedures
• Restricted access systems for sensitive operations
• Regular updates based on geopolitical developments

11. Reporting Suspected Violations

Users and partners may report suspected sanctions violations through:

• Email (Compliance): compliance@nexa-group.org
• Legal Office: legal@nexa-group.org
• Security Team: security@vexor.to

12. Penalties for Violations

Violating sanctions or export control laws may result in:

• Immediate account suspension or termination
• Confiscation of monetized earnings subject to legal requirements
• Permanent bans across all Nexa Group platforms
• Reporting to international authorities
• Civil or criminal penalties under applicable laws

13. Updates to This Policy

This policy may be updated to reflect:

• Changes in international sanctions regimes
• New export control requirements
• Geopolitical developments and regulatory guidance
• Internal compliance improvements

Updated versions will be published with revision timestamps for transparency.