Appetite and restrictions on nationalities and residencies

Omnidrive LT UAB has a clearly defined appetite for which countries and nationalities it wishes to serve. The reason being the company has obligations in order to fulfill its license as a VASP (Virtual Asset Service Provider). As part of this we are obligated to uphold current sanctions regimes subject to the country it operates from, Lithuania. As such, Omnidrive LT UAB ́s market appetite is restricted to the European Economic Area (EEA https://trade.ec.europa.eu/access-to-markets/en/content/european-economic-area-eea-agreement). If any EEA country is put on any of the below sanctions and Risk-lists, the listing will prevail, and our appetite will be adjusted accordingly until the country is delisted.

Exceptions: We are able to serve individuals who are nationals and residents of countries identified as “low risk” and free of sanctions. However, this is only on a case-by-case basis and is dependent on us approving the Enhanced Due Diligence needed to accept and transact such clients.

For a full overview of relevant sanctions lists and countries, please see the following lists and their reasoning:

EU Sanctions

• Reasoning: https://www.eeas.europa.eu/eeas/european-union-sanctions_en
• Map: https://www.sanctionsmap.eu/#/main

OFAC sanctions

• List: https://ofac.treasury.gov/sanctions-programs-and-country-information

UN sanctioned countries and people

• Active UN sanctions: https://www.un.org/securitycouncil/sanctions/2653/materials

FATF

• High risk countries: https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html
• “Black & Grey” list for AML/CTF: https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html