Restricted Jurisdictions

1. Purpose

Roca VC Limited does not provide products or services in a country, territory, or situation where doing so would be unlawful, prohibited, subject to sanctions, or outside the company's regulatory permissions and risk appetite. This Restricted Jurisdictions Policy applies to website visitors, applicants, clients, beneficial owners, representatives, counterparties, partners, and persons seeking to use Roca VC services.

2. No service where prohibited

Roca VC Limited may refuse or restrict a relationship where a person:

• Resides in a prohibited jurisdiction;
• Is physically located in a prohibited jurisdiction;
• Is a citizen or national subject to applicable restrictions;
• Is incorporated or registered in a prohibited jurisdiction;
• Has significant business activity in a prohibited jurisdiction;
• Is controlled by a sanctioned or restricted person;
• Uses a payment method connected to a prohibited jurisdiction;
• Attempts to avoid geographic restrictions; or
• Would cause Roca VC Limited or a service provider to breach law.

A person must not use a VPN, proxy, false address, nominee, intermediary, or third party to conceal their true location, nationality, residence, ownership, or control.

3. Sanctioned persons and entities

Roca VC Limited does not knowingly provide services to a person or entity subject to applicable asset freezes, financial sanctions, trade restrictions, or terrorism-related designations. Screening may include relevant United Kingdom, United Nations, and other legally applicable sanctions lists. A transaction may be blocked, frozen, rejected, or reported where required.

4. Categories of restricted jurisdiction

A jurisdiction may be restricted because:

• Financial products cannot legally be offered there;
• Roca VC Limited lacks the required local permission;
• The country is subject to sanctions;
• The country is identified as presenting unacceptable AML or terrorist-financing risk;
• Payments or banking cannot be supported;
• A platform, liquidity provider, custodian, or counterparty does not support the country;
• Local law prohibits the relevant product;
• The jurisdiction restricts derivatives, leveraged trading, digital assets, or foreign investment; or
• Roca VC Limited decides that the legal, operational, or commercial risk is unacceptable.

5. Approved restricted-country schedule

The definitive country schedule is approved by Roca VC Limited's legal and compliance team and applied consistently across the website and the onboarding system. It distinguishes between:

Fully restricted jurisdictions

No onboarding, trading, investment, liquidity, partnership, or payment service. This includes countries and territories subject to comprehensive sanctions.

Product-restricted jurisdictions

Certain services or instruments (such as CFDs, leverage, digital assets, or investments) are unavailable.

Institutional-only jurisdictions

Services may be available only to eligible professional, institutional, or corporate clients.

Enhanced-due-diligence jurisdictions

Applications require additional review and are not automatically accepted.

The current approved schedule is available on request and is kept up to date as sanctions, regulation, and service-provider policies change.

6. United Kingdom

United Kingdom access is assessed separately for each product. A UK visitor is not offered a regulated product, investment, derivative, or qualifying cryptoasset promotion unless a lawful financial-promotion route is available; the relevant service may legally be provided; required risk warnings are displayed; client classification and appropriateness requirements are met; and the responsible entity and regulatory status are clearly disclosed.

7. United States and other highly regulated markets

No service is offered in the United States, its territories, or another jurisdiction requiring local registration unless legal counsel confirms that the relevant service is permitted and all required registrations are held. The approved country schedule clearly states whether residents, citizens, companies, and persons physically present in these markets are restricted.

8. Changes of residence or location

Clients must promptly inform Roca VC Limited if their residence, citizenship, tax residence, company registration, control, or primary business location changes. A change may affect service availability. Roca VC Limited may restrict or terminate a relationship if a client moves to or becomes connected with a prohibited jurisdiction.

9. Travel

Temporary travel to a restricted jurisdiction may affect access to accounts, platforms, payments, or support. Access may be blocked even where the client's permanent residence has not changed. Clients should contact support before travelling where uninterrupted access is important.

10. Payment and banking restrictions

A country may be restricted even if it is not listed as a fully prohibited jurisdiction where banks cannot process the payment; the payment provider does not support the region; the funding source cannot be verified; sanctions or correspondent-banking concerns arise; digital-asset transfers present unacceptable risk; or local currency controls apply.

11. No right to onboarding

Submission of an application does not create a right to receive services. Roca VC Limited may decline an application based on jurisdiction, risk, product availability, legal advice, or service-provider requirements. Where permitted, a general explanation may be provided. Detailed compliance reasoning may remain confidential.

12. Client confirmation

By applying for or using a service, you confirm that the information you provide is accurate; you have disclosed your true residence and nationality; you are not acting for an undisclosed restricted person; you are not attempting to evade sanctions or location controls; your use is lawful; and you will notify Roca VC Limited if your circumstances change.

13. Updates

Restricted-jurisdiction rules may change without advance notice because of sanctions, regulation, banking arrangements, service-provider policy, or internal risk decisions. The most recent approved version will apply.

Contact

Questions about jurisdiction eligibility may be sent to:

Roca VC Limited Compliance email: compliance@rocavc.com Telephone (UK): +44 7474 625779 Registered office: England, United Kingdom Website: https://rocavc.com