Global Acceptable Use Policy

1. Introduction

This Global Acceptable Use Policy (the “Policy” or “AUP”) establishes the risk appetite of GOAT Finance in relation to:

1. countries and jurisdictions;

2. industries and business activities;

3. occupations and professional activities of individuals; and

4. individual customer characteristics that present a heightened vulnerability to financial exploitation or misuse.

For purposes of this Policy, “GOAT Finance” means Balansas LLC and the participating GOAT Finance entities operating under the GOAT Finance Global Terms and Conditions, as applicable to the relevant onboarding, service or transaction.

This Policy applies to applicants, Customers, beneficial owners, controllers and other persons whose risk profile is relevant to a GOAT Finance relationship.

The methodology used to establish and approve the classifications contained in Version 1 is documented separately in Compliance Memorandum No. HC-013-2026.

GOAT Finance applies three classifications under this Policy:

Any country, industry, activity, occupation or individual customer characteristic not identified in this Policy is not automatically considered Low Risk. It remains subject to GOAT Finance’s ordinary customer risk assessment, applicable law, sanctions requirements and relevant provider restrictions.

A stricter requirement imposed by applicable law, sanctions, a regulator, banking partner, payment provider, liquidity provider or other relevant service provider shall prevail over this Policy. Where more than one classification applies, the stricter classification prevails.

GOAT Finance may decline any relationship where the residual risk cannot reasonably be understood, verified or mitigated.

2. Countries and Jurisdictions

A country connection may arise from residence, incorporation, principal place of business, operations, source or destination of funds, banking relationships or other material geographic exposure. Nationality alone does not determine a Customer’s classification unless required by applicable law or sanctions.

2.1 Prohibited Countries and Jurisdictions

• Democratic People’s Republic of Korea (DPRK)
• Iran
• Myanmar

2.2 High-Risk Countries and Jurisdictions

• Algeria
• Angola
• Benin
• Bolivia
• Bosnia and Herzegovina
• Bulgaria
• Cambodia
• Cameroon
• Central African Republic
• Chad
• China
• Comoros
• Côte d’Ivoire
• Democratic Republic of the Congo
• Djibouti
• Equatorial Guinea
• Eswatini
• Gabon
• Guinea
• Guinea-Bissau
• Haiti
• Iraq
• Kenya
• Kuwait
• Lao PDR
• Lebanon
• Liberia
• Madagascar
• Mali
• Mauritania
• Monaco
• Mozambique
• Nepal
• Nicaragua
• Niger
• Nigeria
• Papua New Guinea
• Republic of the Congo
• Sierra Leone
• Solomon Islands
• South Sudan
• Suriname
• Syria
• Tajikistan
• Togo
• Turkmenistan
• United Arab Emirates
• Venezuela
• Vietnam
• Virgin Islands (UK) / British Virgin Islands
• Yemen

3. Industries and Business Activities

3.1 Prohibited Industries and Business Activities

GOAT Finance will not knowingly provide Services for, or establish a relationship principally involving, any of the following:

• Money laundering, terrorist financing or proliferation financing
• Sanctions evasion or circumvention
• Fraud, scams, Ponzi schemes or pyramid schemes
• Bribery, corruption or tax evasion
• Human trafficking, sexual exploitation or child exploitation
• Illegal narcotics or controlled-substance trafficking
• Illegal arms, weapons or prohibited military-goods trafficking
• Trafficking in stolen, counterfeit or illicit goods
• Illegal wildlife trafficking or other serious environmental crime
• Cybercrime, ransomware or darknet-market activity
• Illegal or unlicensed gambling
• Unlicensed or unauthorized money transmission or MVTS where authorization is required
• Unlicensed or unauthorized payment services
• Unlicensed or unauthorized virtual-asset services where authorization or registration is required
• Unlicensed or unauthorized investment, securities or financial services
• Shell banks
• Businesses established or operated to conceal beneficial ownership, source of funds or the true parties to transactions
• Any business or activity whose principal purpose is to evade AML/CFT, sanctions, onboarding or transaction-monitoring controls

A lawful business is not prohibited solely because its sector may also be vulnerable to criminal misuse.

3.2 High-Risk Industries and Business Activities

The following legitimate activities are classified as High Risk and require EDD and Compliance approval:

• Casinos, gambling and gaming
• Money or Value Transfer Services (MVTS), remittance and money transmission
• Virtual Asset Service Providers (VASPs) and cryptoasset businesses
• Real estate businesses and intermediaries
• Dealers, brokers, refiners and traders in precious metals and precious stones
• Trust and Company Service Providers (TCSPs)
• Lawyers, notaries and other independent legal professionals performing FATF-covered gatekeeper activities
• Accountants and auditors performing FATF-covered activities
• Securities, brokerage and investment-intermediation businesses
• Art, antiquities and high-value collectible businesses
• Non-profit organisations assessed as presenting heightened terrorist-financing exposure

A High-Risk classification does not mean that the business is prohibited or presumed suspicious. Acceptance remains subject to the specific Customer, ownership, licensing, geography, source of funds, source of wealth, expected transaction profile and GOAT Finance’s ability to mitigate the identified risks.

4. Occupations for Individuals

4.1 Prohibited Occupations

GOAT Finance does not prohibit any lawful occupation solely because of its professional title.

An individual is nevertheless treated as Prohibited where the individual’s occupation or principal professional activity:

• is illegal;
• requires a licence or authorization that the individual does not hold;
• materially consists of a Prohibited Activity under Section 3.1;
• involves sanctions evasion, financial crime or deliberate concealment of ownership or funds; or
• otherwise cannot lawfully be supported by GOAT Finance.

4.2 High-Risk Occupations and Functions

The following occupations or functions are treated as High Risk where applicable:

• Head of State or Head of Government
• Senior politician
• Senior government official
• Senior judicial official
• Senior military official
• Senior executive of a state-owned enterprise
• Important political party official
• Senior director, deputy director, board member or equivalent senior official of an international organisation
• Professional trustee, nominee director/shareholder, company-formation agent or other TCSP professional
• Lawyer, notary or independent legal professional performing FATF-covered gatekeeper activities
• Accountant or auditor performing FATF-covered activities
• Real estate broker or agent materially involved in property transactions
• Dealer, broker, refiner, jeweller or professional intermediary in precious metals or precious stones
• Casino or gambling operator or controller
• Professional money-transfer, remittance or MVTS operator
• Owner, controller or operator of a VASP or other virtual-asset business
• Art or antiquities dealer, broker or other professional high-value art intermediary

For professional categories other than PEPs, the classification focuses on the actual activity performed rather than the job title alone. An employee with no ownership, control or involvement in the relevant high-risk activity is not automatically classified as High Risk merely because the employer operates in a High-Risk sector.

A High-Risk occupation requires proportionate EDD, which may include verification of occupation, employer or business activity, source of funds, source of wealth, public-function exposure, licensing or professional registration, and any other information reasonably required to understand and mitigate the risk.

5. Individual Customer Characteristics

A Customer is not classified as High Risk by reason of age alone. GOAT Finance nevertheless recognises that certain individual characteristics may increase a Customer’s exposure to financial exploitation, undue influence, or misuse of the relationship by third parties.

A Customer who is 65 years of age or older is classified as Restricted under this Policy, on the basis of a heightened vulnerability factor. Where that classification applies, GOAT Finance applies proportionate EDD, which may include: (a) confirmation that the Customer, and not a third party, controls the account and instructs transactions; (b) verification of source of funds and source of wealth where the expected transaction profile is inconsistent with the Customer’s stated circumstances; (c) review of any power of attorney, authorised representative, joint account controller or third-party device or credential access; (d) enhanced monitoring for patterns consistent with elder financial exploitation, romance or investment fraud, or money-mule activity; and (e) Compliance approval where the identified vulnerability cannot reasonably be understood, verified or mitigated. Notwithstanding recommendations provided in this section, EDD measures are subject to final policies approved by GOAT Finance.

Where the Restricted classification is combined with another High-Risk classification under this Policy, or where the indicators described above are present and remain unresolved, the relationship is treated as High Risk and requires EDD, Compliance approval and enhanced monitoring as appropriate.

This Section does not authorise the refusal, restriction or termination of a relationship on the basis of age alone. Any decision to decline or exit must be based on the residual risk assessed under this Policy and must comply with applicable law on non-discrimination and access to financial services.