Sanctions Policy

This Sanctions Policy (the "Policy") sets out the general principles for complying with applicable sanctions laws and restrictions in connection with the use of Nexelorant (the "Platform").

By using Nexelorant, the user confirms that they have read this Policy, understand its terms, and agree to comply with its provisions.

Nexelorant seeks to comply with applicable international sanctions regimes, including, without limitation, those administered by the United Nations, the European Union, the United States of America, including OFAC, and the United Arab Emirates.

Applicable sanctions restrictions are determined by the relevant competent authorities and may be imposed, amended, expanded, or lifted without notice. The user bears sole responsibility for ensuring that their access to and use of the Platform complies with all applicable sanctions laws, restrictions, and export-control requirements.

By using the Platform, the user represents and warrants that they are not the subject of any applicable sanctions, do not act on behalf of or for the benefit of any sanctioned person or entity, are not located, organized under the law of, or ordinarily resident in a jurisdiction subject to comprehensive sanctions, to the extent that such use would violate applicable law, and that their use of the Platform does not violate any applicable sanctions laws or export-control laws.

The user further confirms that they will not use the Platform in any way that could cause Nexelorant or any related service provider to violate applicable sanctions laws or restrictions.

The user may not use Nexelorant in any way that would violate applicable sanctions laws. This includes any use involving sanctioned persons or entities, any activity restricted or prohibited under applicable sanctions regimes, and any attempt to circumvent or evade sanctions restrictions, including through technical means intended to conceal identity, jurisdiction, residence, or location.

Any use of the Platform to facilitate, support, enable, or conceal conduct prohibited by sanctions law is strictly prohibited.

Nexelorant is a technology ecosystem of products and infrastructure. In its supported smart-contract scenarios, deal funds are handled according to predefined logic, without Nexelorant taking them into intermediary custody. The Platform has no access to users' private keys and cannot create signatures on their behalf. Technical infrastructure may only initiate the technical state transitions the code provides for; this gives it no right to change a deal's parameters arbitrarily or to dispose of funds outside the contract's logic.

The Platform does not act as an intermediary in the traditional legal sense and assumes no obligations of a financial institution. The Platform does not participate as a legal counterparty to deals between users. Actions that require user authorization are confirmed using the corresponding wallet; in the current implementation, TON Connect is used for this. Such authorization is distinct from the infrastructure's permitted technical messages, as further described in the User Agreement and the Privacy Policy.

Nexelorant may take reasonable measures to ensure compliance with applicable sanctions laws, including restricting or terminating access to the Platform's interface, restricting access to or interaction with specific services, addresses, territories, or interfaces, and refusing service where there are reasonable grounds to suspect a violation of sanctions laws or related restrictions.

Nexelorant may apply such measures in accordance with applicable law and its internal compliance procedures, and, where permitted, without prior notice. Nexelorant may also rely on information from third-party providers, public sources, technical monitoring tools, or compliance-related risk indicators when assessing whether a restriction is warranted.

Given the decentralized, open, and technically limited nature of blockchain networks, Nexelorant does not guarantee the ability to identify, verify, block, or prevent every interaction with sanctioned persons, entities, jurisdictions, or wallet addresses.

The user acknowledges and accepts that compliance with sanctions law remains their own responsibility, and that using the Platform is not any representation by Nexelorant that a particular transaction, counterparty, wallet address, or jurisdiction is lawful, unrestricted, or compliant with applicable law. Nexelorant makes no representation that interacting with specific users or addresses complies with applicable sanctions requirements.

Nexelorant bears no responsibility for any losses, damage, costs, or consequences arising from a user's breach of applicable sanctions laws, from restrictions or measures imposed by third parties, regulators, infrastructure providers, wallet providers, blockchain protocols, or government authorities, or from being unable to access or use the Platform as a result of compliance-related restrictions or risk-control measures.

The user understands and accepts that access to the Platform may be suspended, restricted, or terminated if Nexelorant considers this necessary to comply with applicable sanctions requirements or to reduce legal, regulatory, or reputational risk.

Nexelorant reserves the right to amend this Policy at any time.

The updated version takes effect upon publication, unless stated otherwise. Continuing to use the Platform constitutes acceptance of the updated Policy.

For questions related to this Policy, the user may contact Nexelorant through the Platform's interface or the official contact channels Nexelorant provides.