RYPLEX SOLUTIONS LTD.
Restricted Jurisdictions and Access Control Policy
How Ryplex Solutions Ltd. controls access to its website, platform, products, and
related services across countries and territories.
- Corporate Number: 1001543287
- Registered Office: 1110 Finch Avenue West, Unit 1293, North York, Ontario, M3J2T2,
1. Policy Overview
This Restricted Jurisdictions and Access Control Policy explains how Ryplex Solutions Ltd. (“Ryplex”,
“Company”, “we”, “us”, or “our”) controls access to its website, platform, products, and related services.
The Company does not make its services available in every country or territory. Access may be
restricted where a jurisdiction presents heightened legal, sanctions, anti-money laundering, counter-
terrorist financing, fraud, regulatory, or operational risk.
This Policy is intended to protect the Company, its customers, its financial partners, and the integrity of
its services from exposure to prohibited or unsupported jurisdictions.
2. Customer Confirmation
By accessing or using the Company’s website or services, each customer confirms that they are not:
- located in a restricted jurisdiction;
- ordinarily resident in a restricted jurisdiction;
- a citizen or national of a restricted jurisdiction where such restriction applies;
- using the services on behalf of a person located in a restricted jurisdiction;
- attempting to bypass access controls through false information or technical tools.
Where any of the above becomes inaccurate, the customer must immediately stop using the services
and notify the Company.
3. Regulatory Basis
Ryplex Solutions Ltd. applies jurisdictional restrictions with reference to applicable legal and
compliance standards, including but not limited to:
- Canadian anti-money laundering and counter-terrorist financing requirements;
- Canadian sanctions legislation and government guidance;
- FINTRAC expectations and reporting obligations, where applicable;
- FATF statements regarding high-risk and monitored jurisdictions;
- United Nations Security Council sanctions regimes;
- international sanctions programmes, including OFAC-related restrictions where relevant;
- requirements imposed by banking, payment, liquidity, compliance, or technology partners.
The Company may apply stricter internal controls than the minimum required by law where reasonably
necessary.
4. Restricted and Unsupported Jurisdictions
Ryplex Solutions Ltd. may prohibit or limit access from countries and territories that are sanctioned,
high-risk, commercially unsupported, or otherwise inconsistent with the Company’s risk appetite.
The following jurisdictions are currently restricted or subject to limitations.
Africa: Algeria, Angola, Botswana, Burkina Faso, Burundi, Cameroon, Central African Republic, Chad,
Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guinea, Guinea-Bissau,
Ivory Coast / Côte d’Ivoire, Liberia, Libya, Mali, Mauritania, Morocco, Mozambique, Namibia, Nigeria,
Sierra Leone, Somalia, South Sudan, Sudan, Togo, Tunisia, Uganda, Zambia, and Zimbabwe.
Middle East and North Africa: Afghanistan, Bahrain, Egypt, Gaza Strip / Palestinian Territories, Iran,
Iraq, Jordan, Kuwait, Lebanon, Saudi Arabia, Syria, United Arab Emirates where specific restrictions
apply, and Yemen.
Asia-Pacific: Bangladesh, Bhutan, Cambodia, Mainland China, Fiji, India where service limitations apply,
Indonesia where service limitations apply, Kazakhstan where service limitations apply, Kyrgyzstan,
Laos, Maldives, Myanmar / Burma, Nepal, North Korea, Pakistan, Papua New Guinea, Sri Lanka,
Tajikistan, Turkmenistan, Uzbekistan, Vanuatu, and Vietnam.
Europe and Eurasia: Belarus, Bosnia and Herzegovina, Kosovo, Russian Federation, Serbia where
service limitations apply, Turkey, and occupied territories of Ukraine, including Crimea, Donetsk, and
Luhansk, United Kingdom, Monaco, Bulgaria.
Americas: Argentina, Bolivia, Brazil, Colombia, Costa Rica, Cuba, Ecuador, El Salvador, Guatemala,
Guyana, Haiti, Honduras, Jamaica, Mexico, Nicaragua, Panama, Paraguay, Peru, Suriname, Trinidad and
Tobago, United States of America including all states and territories, and Venezuela.
Other Territories and Regions: British Virgin Islands, Puerto Rico, Guam, Northern Cyprus, Western
Sahara, and Vatican City.
5. Limited-Service Jurisdictions
Certain jurisdictions may not be fully prohibited but may be subject to additional conditions, reduced
functionality, lower limits, enhanced due diligence, or manual approval.
The Company may classify a jurisdiction as limited-service where:
- local regulation is unclear or changing;
- banking partners impose restrictions;
- transaction monitoring indicates elevated risk;
- sanctions exposure requires additional review;
- service availability is commercially or operationally limited.
Ryplex Solutions Ltd. may refuse or delay transactions from such locations even where account access
has not been fully blocked.
6. Access Control Measures
The Company may apply several technical and administrative controls to enforce this Policy, including:
Location Screening. Reviewing country of residence, nationality, address information, phone number
country codes, and other onboarding data.
IP and Device Controls. Identifying and blocking access attempts from restricted regions through IP
address analysis, geolocation tools, device signals, and security systems.
Payment and Wallet Screening. Reviewing payment accounts, bank details, wallet addresses,
counterparties, and transaction routes for restricted jurisdiction exposure.
Ongoing Monitoring. Reassessing customer location data and transaction behaviour throughout the
business relationship.
Manual Compliance Review. Escalating uncertain or higher-risk cases to compliance personnel before
access or transactions are approved.
7. Prohibited Circumvention
Customers must not attempt to avoid or bypass jurisdictional restrictions.
Prohibited conduct includes, without limitation:
- use of VPNs, proxies, anonymizers, or masking tools;
- submission of false address, nationality, or residence information;
- use of intermediaries or nominees to access services;
- routing payments through unrelated third parties;
- concealing the true origin or destination of funds;
- accessing the Platform while physically located in a restricted region.
Any such conduct may be treated as a material breach of Company policy and customer terms.
8. Transactions Involving Restricted Jurisdictions
The Company may reject, hold, reverse, freeze, or report any transaction that appears to involve a
restricted jurisdiction, whether directly or indirectly.
This may include transactions involving:
- customers located in restricted countries;
- counterparties based in restricted countries;
- banks or payment institutions operating in restricted countries;
- wallet addresses connected to sanctioned or high-risk regions;
- intermediary entities used to conceal jurisdictional exposure.
The Company may also request supporting documentation to determine the true nature and
geographic connection of a transaction.
9. Consequences of Breach
Where a customer breaches this Policy or attempts to circumvent access restrictions, Ryplex Solutions
Ltd. may take immediate action, including:
- refusing onboarding or account activation;
- suspending or terminating account access;
- cancelling pending transactions;
- freezing funds where legally required or justified by risk;
- requesting additional verification documents;
- notifying banks, payment partners, regulators, law enforcement, or FINTRAC where required;
- permanently prohibiting future use of the services.
The Company may be restricted by law from providing detailed explanations where compliance,
sanctions, or law enforcement considerations apply.
10. Review of Restricted Jurisdiction List
The list of restricted jurisdictions is reviewed periodically and may be updated without prior notice.
Updates may be made due to:
- sanctions changes;
- FATF publications;
- Canadian regulatory developments;
- banking or payment partner requirements;
- internal risk assessments;
- fraud or abuse trends;
- changes in local laws.
A country or territory not expressly listed may still be refused where the Company determines that
servicing it would create unacceptable risk.
11. No Waiver or Right to Service
The absence of a technical block does not mean that a customer is eligible to use the Company’s
services.
Similarly, previous access to the Platform does not create a right to continued service if the customer
later becomes connected to a restricted jurisdiction or if the Company’s risk assessment changes.
Ryplex Solutions Ltd. reserves the right to refuse service at its discretion where permitted by law.