GEOBLOCKING & RESTRICTED JURISDICTIONS POLICY
Paliton s.r.o.
Last updated: 02.12.2025
1. Purpose of This Policy
This Geoblocking & Restricted Jurisdictions Policy (“Policy”) explains the territorial limitations under which Paliton s.r.o. (“Paliton”, “we”, “our”) provides its Services.
As a Virtual Asset Service Provider incorporated in the Slovak Republic, Paliton must comply with European Union legislation, Slovak national laws, FATF recommendations, international sanctions regimes, and risk-based compliance obligations.
Because of these legal and regulatory requirements, certain countries, territories, and categories of users cannot access or use our Services, either entirely or partially.
This Policy also explains how we technically block access, how we verify user location, and what actions may occur if a user attempts to bypass these restrictions.
2. General Principle of Territorial Restrictions
Paliton’s Services are designed exclusively for Clients who reside in jurisdictions where the provision of virtual asset services is lawful and permissible. We do not knowingly onboard or serve individuals or entities located in countries where:
• virtual asset services are prohibited or restricted by law;
• sanctions regimes prohibit transactions, financial cooperation, or commercial activity;
• regulatory or AML/CTF risk is deemed unacceptably high; Paliton is unable to fulfil its compliance, verification, or reporting obligations;
• The financial system does not meet the minimum standards required by EU AML Directives and FATF recommendations.
For compliance, Paliton may implement IP-based geoblocking, GPS-based checks (where applicable), payment-method restrictions, and document verification, as well as ongoing monitoring of activity patterns.
3. Restricted Jurisdictions
3.1. Sanctioned Countries and Territories
Paliton does not provide Services to any person residing in, located in, or associated with jurisdictions
subject to comprehensive international sanctions, including (but not limited to):
• Countries subject to EU restrictive measures
• Countries under UN Security Council sanctions
• Jurisdictions under broad financial sanctions by the European Union
• Countries or territories where Paliton is legally prohibited from providing financial services
Paliton screens all users and transactions against international sanctions databases.
3.2. High-Risk or Non-Cooperative Jurisdictions
We may restrict or prohibit access from countries identified as:
• High-Risk Third Countries under EU AML rules
• FATF High-Risk Jurisdictions subject to a call for action
• FATF “Grey List” jurisdictions where AML/CTF deficiencies are significant
• Regions where regulatory frameworks are insufficient to support compliance obligations
The risk-based approach may result in full prohibition or severe access limitations.
3.3. Jurisdictions Prohibiting or Restricting Virtual Asset Services
If local law prohibits the use of cryptocurrency exchanges or virtual asset service providers, Paliton
cannot offer services in such locations.
It is the Client’s obligation to ensure their use of Paliton does not violate their own local laws.
4. Verification of Location and Residency
To comply with this Policy, Paliton may verify a user’s location through several mechanisms:
IP address analysis and geoblocking
• Document verification (residence, citizenship, national ID)
Payment method checks
• Device location indicators
• Blockchain or transactional patterns suggesting prohibited territory activity
If information received during verification is inconsistent (e.g., European passport but repeated access from a sanctioned jurisdiction), Paliton may require additional documents or explanations, suspend the account, or terminate the relationship.
Attempting to falsify residency or circumvent geoblocking is prohibited.
5. Prohibition on VPN, Proxies, and Obfuscation Tools
Clients are strictly prohibited from:
• Using VPNs, proxies, Tor networks, or any tools intended to hide or falsify actual geolocation
• Providing misleading residency documentation
• Accessing our Services from a restricted jurisdiction using technology to bypass controls
If Paliton detects such attempts, we may:
Suspend or permanently close the account
• Block transactions, including pending withdrawals
Request additional verification
Report the activity to competent authorities where required by law
6. Reassessment of Jurisdictions & Continuous Monitoring
Geopolitical conditions, sanctions regimes, and regulatory frameworks evolve.
Therefore, Paliton continually reassesses its permitted and restricted jurisdictions based on:
• EU regulatory updates
• Slovak national law
• FATF statements
• International sanctions alerts
• Internal risk assessments
As a result, Paliton may:
• Add or remove jurisdictions from the restricted list
• Adjust service availability (full ban, partial restrictions, transaction limits)
• Require additional documentation from existing Clients
Request Clients to close or migrate accounts when ongoing access is no longer legally permissible
Changes to this Policy are effective immediately upon publication.
7. Consequences of Using the Services from a Restricted Jurisdiction
If Paliton determines that a Client resides in, relocates to, or accesses the platform from a restricted jurisdiction, we may:
Restrict logins or block access to the account
Freeze or refuse to execute transactions
Request updated identity or residency documents
• Terminate the business relationship
• Retain records as required by AML/CTF law
• Comply with reporting obligations toward competent authorities
Withdrawals may be permitted only if legally permissible and not prohibited by sanctions.
8. Client Responsibilities
Clients must:
• Provide accurate and truthful information regarding their residency and location
• Inform Paliton immediately if their residency changes
• Ensure compliance with the laws applicable in their own jurisdiction
• Not attempt to bypass geoblocking or compliance restrictions
Failure to comply may result in service termination, reporting duties, and permanent prohibition from using Paliton’s Services.