Important Information About EU Sanctions and Certain Crypto-Asset Services

European Union ("EU") sanctions laws can restrict or prohibit certain transactions involving specific individuals, companies, platforms or services.

As a company established and operating in Ireland, Payward Europe Solutions Limited ("PESL") must comply with EU sanctions.

These sanctions also apply to PESL clients, including individuals, when using our services.

A breach of sanctions law is a criminal offence.

The EU has introduced new measures that prohibit PESL and its clients from engaging, directly or indirectly, in transactions involving certain crypto-asset service providers and platforms.

These restrictions currently apply to:

Russian crypto-asset service providers and Russian crypto-asset platforms or exchanges. [Article 5bb];

Certain crypto-asset and payment service providers identified by the EU as frustrating EU sanctions or supporting Russia's war against Ukraine, as well as any successor, mirror, or other services acting on their behalf. [Article 5ad – Part A, Part B, C, D Annex XLV]

This currently includes Payeer and, from 23 August 2026, will also include:

  • Rapira

  • Aifory Pro (Sooty Ltd.)

  • ABCeX (Nueva Cryptologia S.A.S DE C.V.)

  • WhiteBird

  • NoOnecrypto INC.

  • Tradex (Brightum LLC)

  • Monease Ltd

  • BitPapa

  • Exnode / Exnode Pay (Arvix)

  • HTX (HUOBI GLOBAL SA)

  • EXMO Ltd

Crypto-asset service providers and platforms established in certain countries identified by the EU as failing to prevent them from frustrating EU sanctions. [Article 5bc]

The countries that will be subject to these measures have not yet been specified by the EU.

It is prohibited to transact directly with a prohibited platform, but also to transact with parties using a prohibited platform to send or receive crypto-assets. This prohibition to transact with a prohibited platform applies to PESL and it may also apply to you, and you may need to review your current holdings and planned transactions and to seek independent legal advice on your own position.

To comply with these EU sanctions requirements, PESL must:

  • reject outgoing transfers to prohibited platforms; and

  • block and freeze incoming transfers from prohibited platforms.

Where assets are received from a prohibited platform, PESL is unable to:

  • return them to the prohibited platform; or

  • release them to a client's wallet address,

unless permitted under applicable sanctions laws.

In limited circumstances, an exception to the transaction ban may apply, or a licence may be sought from a relevant EU authority to permit a transaction.

You should seek independent legal advice before transacting with a prohibited platform or party using one of those services to confirm whether an exception or licencing ground would apply.

As set out in our Terms and Conditions, PESL is committed to complying with all applicable legal and regulatory requirements, including EU sanctions laws, and will take all measures necessary to ensure compliance. This may include rejecting transactions, freezing assets or restricting account activity.

PESL closely monitors its legal and regulatory obligations and related regulatory guidance. Should its approach to transactions with prohibited platforms change in line with these obligations or available guidance, PESL will issue a further client notification.

We appreciate your understanding as we work to meet our legal obligations and help maintain the integrity and security of our platform.