Sanctions Compliance Policy
1. Purpose and scope
Coinwars Inc. is being formed as a Wyoming corporation, and will be a United States company subject to United States economic sanctions law, including the programs administered by the Office of Foreign Assets Control of the United States Department of the Treasury ("OFAC").
Coinwars Inc. has not been formed yet. Until its certificate of incorporation is issued there is no company to be a party to this document, to operate the service, or to owe anybody what is written here.
This policy explains how those laws apply to the Coin Wars website, its programming interfaces and the off-chain services behind them (the "Service"), and it forms part of the Terms of Service.
2. What the law prohibits
United States persons are generally prohibited from dealing with people and entities on the OFAC Specially Designated Nationals and Blocked Persons List (the "SDN List"), and with people located, organised or ordinarily resident in a jurisdiction under comprehensive sanctions. Liability does not depend on intent, so a prohibited dealing can be a violation even when nobody meant to commit one.
An entity owned 50 percent or more, directly or indirectly, in the aggregate, by one or more blocked persons is itself blocked, whether or not it appears on the SDN List.
3. Who may not use the Service
You may not access or use the Service if you are, or if you act for, any of the following:
- a person on the SDN List, or on another OFAC list that prohibits the dealing in question;
- an entity owned 50 percent or more, directly or indirectly, by one or more such persons;
- a person located, organised or ordinarily resident in a jurisdiction on the schedule below, or the government of such a jurisdiction; or
- a person using the Service to evade sanctions, or to help somebody else do so.
You must also comply with any sanctions that apply to you under your own country's law, including those of the United Nations, the European Union and the United Kingdom.
4. Jurisdiction schedule
The Service is not available to anybody located in, or ordinarily resident in, the jurisdictions below, which are subject to comprehensive United States sanctions. This schedule was compiled on 2026-09-10. OFAC's own program pages state the law, and where they differ from this summary, OFAC governs.
| Jurisdiction | Code | Program | Authority |
|---|---|---|---|
| Cuba | CU | Cuban Assets Control Regulations | 31 C.F.R. Part 515 |
| Iran | IR | Iranian Transactions and Sanctions Regulations | 31 C.F.R. Part 560 |
| North Korea | KP | North Korea Sanctions Regulations | 31 C.F.R. Part 510 |
| Syria | SY | Syria sanctions program | 31 C.F.R. Part 542 (under review) |
| Crimea region of Ukraine | UA-43 | Ukraine-/Russia-related sanctions | Executive Order 13685 |
| Sevastopol | UA-40 | Ukraine-/Russia-related sanctions | Executive Order 13685 |
| So-called Donetsk People's Republic (Donetsk region of Ukraine) | UA-14 | Ukraine-/Russia-related sanctions | Executive Order 14065 |
| So-called Luhansk People's Republic (Luhansk region of Ukraine) | UA-09 | Ukraine-/Russia-related sanctions | Executive Order 14065 |
Codes follow ISO 3166. A code with a suffix, such as UA-43, names a region of a country, and the rest of that country is not on this schedule.
Syria: The United States program was substantially revised in 2025. Syria stays on this schedule until counsel confirms the current position.
Confirm this schedule against the current OFAC program list on the day it is published, and again whenever a program changes. A jurisdiction comes off the schedule only after that review, because over-blocking can be undone and under-blocking cannot.
Whether the Service also refuses places that are not comprehensively sanctioned, for example because sanctions risk there is high, is undecided. Until it is decided, nothing is refused on policy grounds alone, and this box says so rather than letting silence imply a considered decision.
5. How the Service applies this policy
The controls below are the controls this Service is being built to apply, and none of them is in operation at this version. They are designed to be reasonable and proportionate to the risk. No control is perfect, and reaching the Service does not mean that anybody has cleared you.
- Location. Requests will be geolocated by network address at the edge, and a request from a jurisdiction on the schedule refused for every page and interface of the Service.
- Circumvention. Using a VPN, a proxy or any other means to disguise where you are in order to reach the Service breaches the Terms, and we may use tools that detect such means.
- Address screening. Wallet addresses that connect to the Service, and addresses named in requests to its programming interfaces, will be screened against the digital currency addresses OFAC publishes on the SDN List, and a match refused.
- Attestation. Accepting the Terms will include confirming that you are not a person this policy excludes.
- Records. Screening results, refusals and the evidence behind them will be kept for as long as United States sanctions recordkeeping rules require.
None of the controls in this section exist in the product at this version: there is no edge location block, no address screening and no attestation. This policy must not be published until they do. A published control that does not operate is worse evidence than no policy at all.
Choose the screening list or vendor, confirm the recordkeeping period under 31 C.F.R. 501.601, and decide whether screening has to cover the other side of a trade as well as the connecting wallet.
6. What this policy cannot do
The smart contracts are public software on a public blockchain. Anybody can call them directly, without the Service. Coinwars Inc. applies this policy to what it operates: the website, its programming interfaces and its off-chain data.
The contracts give Coinwars Inc. no function to freeze coins held in a wallet or to reverse a settled transaction. Refusing access to the Service is the remedy available, and it does not undo anything already recorded on the blockchain.
7. If a person or an address matches
Where screening or other information indicates that a person or an address is excluded by this policy, Coinwars Inc. may, without notice:
- refuse access to the Service;
- hide the related profile, comments and coin pages from the Service;
- keep the related records; and
- report to OFAC or to another authority where the law requires it, including reports of blocked property and of rejected transactions under 31 C.F.R. 501.603 and 501.604.
8. If you were refused in error
Location data and screening lists are imperfect, and a legitimate user can be refused. If you believe you were refused in error, tell us your wallet address and the date. We will review it. We cannot give access where the law prohibits it, and we may ask for information showing that you are eligible.
No address exists yet for a sanctions review. Create a monitored mailbox and a postal notice address, set them in the entity configuration, and every document here picks them up.
9. Requests from authorities
Coinwars Inc. responds to lawful requests from government authorities, and may disclose information to OFAC or to law enforcement where the law requires it, or where it believes in good faith that disclosure is needed to comply with sanctions law. The Privacy Policy describes what information exists to disclose.
10. Changes to this policy
Sanctions programs change. When one that affects the schedule changes, this policy is updated and its version number changes.
11. Contact
No address exists yet for questions about this policy. Create a monitored mailbox and a postal notice address, set them in the entity configuration, and every document here picks them up.