SPRUT GAMING

Software Provider — iGaming Technology

GEO-RESTRICTION & COMPLIANCE POLICY

Restricted Jurisdictions · Operator Obligations · Disconnection Protocol

sprutgaming.com · Version 1.0 · Effective 2025 · Public Document

FUNDAMENTAL POSITION — SOFTWARE PROVIDER ONLY

Sprut Gaming operates exclusively as a technology and software provider. Sprut Gaming licenses platform software, APIs, back-end infrastructure and related technology services to independent operators on a B2B basis. Sprut Gaming does NOT operate gambling services, does NOT accept wagers, does NOT hold end-user funds, and does NOT hold any gaming licence in respect of end-user activity. Sprut Gaming bears NO civil, criminal, regulatory or administrative liability whatsoever for any violation of gambling laws, payment regulations, AML/CFT obligations or any other legal or regulatory requirement arising from the activities of any Operator or its end-users in any jurisdiction, including any Restricted Jurisdiction listed in this Policy. Full and exclusive legal responsibility for regulatory compliance rests solely with the Operator.

SECTION 01

PURPOSE & LEGAL FRAMEWORK

This Geo-Restriction & Compliance Policy ("Policy") is a public document published by Sprut Gaming. It sets out: (i) the Restricted Jurisdictions in which Operators are prohibited from using Sprut Gaming's software; (ii) the technical and contractual obligations applicable to all Operators; and (iii) the disconnection procedure applicable upon any breach.

This Policy forms an integral part of every Software Usage Agreement between Sprut Gaming and any Operator. By entering into a Software Usage Agreement, the Operator confirms it has read, understood and agreed to this Policy. In the event of any conflict, this Policy prevails. Continued use of Sprut Gaming's software following publication of an updated version constitutes unconditional acceptance of the updated terms.

SECTION 02

SPRUT GAMING'S ROLE — SOFTWARE PROVIDER

2.1 Technology Services Only

Sprut Gaming provides software, APIs, back-end infrastructure and white-label iGaming solutions to independent operators on a B2B basis only.
Sprut Gaming is not an online gambling operator and does not hold any B2C gaming licence
Sprut Gaming does not control, direct or supervise the commercial or operational activities of any Operator.
Sprut Gaming does not process end-user payments and does not hold player funds.
Sprut Gaming has no direct legal relationship with the Operator's end-users.

2.2 Express Disclaimer of Liability

LEGAL DISCLAIMER — READ CAREFULLY

Sprut Gaming expressly disclaims all liability — civil, criminal, regulatory, administrative or otherwise — for any act or omission of any Operator or its end-users, including but not limited to: (a) the provision, marketing or facilitation of gambling or gaming services in any jurisdiction; (b) any violation of applicable gambling laws, licensing requirements, AML/CFT rules, payment regulations, data protection legislation or any other regulatory obligation; (c) any breach of the Restricted Jurisdictions provisions of this Policy; (d) any claim brought by a regulatory authority, governmental body or third party arising from the Operator's activities. This disclaimer applies regardless of whether Sprut Gaming was or ought to have been aware of the Operator's activities.

SECTION 03

RESTRICTED JURISDICTIONS

Operators are strictly and absolutely prohibited from using Sprut Gaming's software, platform infrastructure, APIs or any related services to provide, market or facilitate any services — directly or indirectly — to end-users located in or accessing from any Restricted Jurisdiction. This list is OPEN-ENDED and NON-EXHAUSTIVE.

Jurisdiction	Legal Basis	Category
Republic of Armenia	Statutory prohibition on gambling	Statutory Ban
Republic of Azerbaijan	Statutory prohibition on gambling	Statutory Ban
Republic of Belarus	Statutory prohibition on gambling	Statutory Ban
People's Republic of China	Statutory prohibition on gambling	Statutory Ban
Federal Republic of Germany	Mandatory licensing / restricted market	Licence Required
State of Israel	Statutory prohibition on gambling	Statutory Ban
Islamic Republic of Iran	UN / EU / OFAC sanctions + statutory prohibition	Sanctions + Ban
DPRK (North Korea)	UN / OFAC / EU / UK sanctions + prohibition	Sanctions + Ban
Kingdom of the Netherlands	Mandatory licensing / restricted market	Licence Required
Republic of Poland	Mandatory licensing / restricted market	Licence Required
Portuguese Republic	Mandatory licensing / restricted market	Licence Required
Russian Federation	Statutory prohibition + international sanctions	Sanctions + Ban
Kingdom of Spain	Mandatory licensing / restricted market	Licence Required
Republic of Costa Rica	Statutory prohibition on gambling	Statutory Ban
Republic of the Union of Myanmar	FATF High-Risk + statutory prohibition	FATF + Ban
Republic of Uzbekistan	Statutory prohibition on gambling	Statutory Ban
United Kingdom of Great Britain and NI	Mandatory UKGC licensing	Licence Required
United States of America	Federal & state statutory prohibition	Statutory Ban
Republic of Turkey	Statutory prohibition on gambling	Statutory Ban
FATF High-Risk Jurisdictions (dynamic)	FATF Call for Action — applied automatically	Dynamic / FATF
UN / EU / OFAC / UK Sanctioned Territories (dyn.)	All applicable sanctions regimes	Dynamic / Sanctions
Any jurisdiction lacking required licence (dyn.)	Regulatory requirement — licence mandatory	Dynamic / Regulatory

OPEN-ENDED LIST — RIGHT TO UPDATE WITHOUT PRIOR NOTICE

Sprut Gaming reserves the absolute and unconditional right to add, remove or reclassify any jurisdiction at any time, including: (i) any jurisdiction newly included in the FATF High-Risk / Call for Action list; (ii) any new sanctions territory designated by the UN, EU, OFAC, UK HM Treasury or any other competent authority; (iii) any jurisdiction which Sprut Gaming, at its sole discretion, determines presents legal, regulatory, reputational or compliance risk. Named jurisdiction updates take effect upon publication at sprutgaming.com. Dynamic categories (FATF, sanctions) take effect automatically upon official designation — no amendment to this Policy document is required.

SECTION 04

OPERATOR OBLIGATIONS

4.1 Geo-Blocking

Implement IP-level geo-blocking for all Restricted Jurisdictions using a commercial-grade geolocation database updated at minimum weekly.
Conduct account-level jurisdiction verification via KYC document checks at registration.
Block all payment transactions originating from Restricted Jurisdictions at the payment processor level.
Detect and block access via known VPN, proxy and anonymisation exit nodes.
Maintain real-time alerting for access attempts from Restricted Jurisdictions.
Retain all geo-blocking logs and compliance records for a minimum of five (5) years.

Geo-Blocking

ZERO TOLERANCE — VPN / PROXY FACILITATION

The Operator must not knowingly permit, facilitate, encourage or tolerate the use of VPN services, proxy servers, Tor exit nodes or any other anonymisation technology that conceals the end-user's true jurisdiction of access. Detection of deliberate VPN or proxy facilitation constitutes an automatic and irremediable material breach of the Software Usage Agreement and triggers immediate permanent termination of all access to Sprut Gaming's platform — with no right of cure or reinstatement.

4.3 AML / KYC

KYC and AML procedures must exclude from onboarding any individual resident in or accessing from a Restricted Jurisdiction.
All payment transactions linked to Restricted Jurisdictions must be rejected.
AML records must be retained for a minimum of five (5) years.

4.4 Independent Legal Responsibility

The Operator must obtain independent legal advice regarding the lawfulness of its operations in each target jurisdiction BEFORE commencing any activity.
The existence of an offshore gaming licence does not authorise the provision of gambling services in any Restricted Jurisdiction.
The Operator bears sole and exclusive legal responsibility for compliance with all applicable laws in every jurisdiction in which it operates.

SECTION 05

DISCONNECTION PROTOCOL

Upon becoming aware of any actual or reasonably suspected breach of this Policy, Sprut Gaming shall take the following measures immediately, unilaterally, without prior notice, and without incurring any liability to the Operator:

Jurisdiction	Legal Basis	Category
Access from Restricted Jurisdiction detected	Technical suspension of Operator access	Compliance audit within 7 days
Geo-blocking absent or insufficient	Full disconnection from the Platform	Termination of Software Agreement
Payment processing from Restricted Jurisdiction	Suspension + transaction freeze	Termination + refund procedure
VPN / proxy facilitation confirmed	IMMEDIATE PERMANENT TERMINATION	Referral to competent authorities
Repeated or wilful breach	IMMEDIATE PERMANENT TERMINATION	Indemnity claim and legal action
Activity in a sanctioned jurisdiction	IMMEDIATE PERMANENT TERMINATION	Regulatory disclosure if required

RIGHT TO IMMEDIATE DISCONNECTION — NO LIABILITY TO OPERATOR

Sprut Gaming may disconnect, suspend or terminate any Operator's access to the platform IMMEDIATELY, unilaterally and without liability, upon becoming aware — or having reasonable grounds to suspect — that the Operator is engaged in or facilitating activity in any Restricted Jurisdiction or is otherwise in breach of this Policy. No prior notice, cure period, mediation or judicial process is required as a precondition for the exercise of this right. Sprut Gaming's right to seek damages and indemnification survives any disconnection or termination.

SECTION 06

INDEMNIFICATION

The Operator shall, at its own cost and expense, fully indemnify, defend and hold harmless Sprut Gaming, its shareholders, directors, officers, employees, agents and successors from and against any and all losses, liabilities, damages, costs and expenses, including:

Fines, penalties and regulatory sanctions imposed by any authority;
Civil judgments, arbitral awards and assessed damages;
Criminal defence costs and all legal fees;
Third-party claims, compensation demands and settlement amounts;
Reputational damage and crisis management expenditure;
Costs incurred by Sprut Gaming in connection with any investigation or regulatory inquiry arising from the Operator's activities;

— arising directly or indirectly from: (i) the Operator's activities in any Restricted Jurisdiction; (ii) any breach of this Policy; or (iii) any violation of applicable law by the Operator or its end-users.

SURVIVAL

Indemnification obligations survive the termination or expiry of the Software Usage Agreement for any reason and are not limited in amount.

SECTION 07

POLICY UPDATES & GOVERNANCE

This Policy is reviewed at minimum once per year and updated as required to reflect changes in applicable law, regulatory guidance, and FATF / sanctions designations.
Sprut Gaming may amend this Policy at any time by publishing an updated version at sprutgaming.com. Named jurisdiction updates take effect upon publication.
Dynamic categories (FATF; UN, EU, OFAC, UK sanctions) apply automatically upon official designation — without amendment to this document.
The most current published version supersedes all prior versions.
Continued use of Sprut Gaming's software following publication of an updated Policy constitutes acceptance of the updated terms.
Compliance enquiries may be directed to Sprut Gaming's Compliance Department via sprutgaming.com.

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