Effective Date: April 1, 2025
Last Updated: March 14, 2026
Section 1: Purpose and Overview
1.1. Introduction
This Restricted Jurisdictions and Geo-Restriction Declaration (hereinafter referred to as "this Declaration") is a legally binding document that forms part of the Zelencio Terms of Service and User Agreement, Privacy Policy, and AML/CTF Compliance Policy. This Declaration governs the geographic availability of the Zelencio platform, its mobile application, and all associated digital asset services operated by DMG Dynasty.
The purpose of this Declaration is to clearly communicate to users, app store reviewers, regulatory bodies, and the general public which countries and jurisdictions are restricted from accessing or using the Zelencio platform, the legal basis for each restriction, and the obligations placed on users in connection with jurisdictional compliance.
1.2. Scope of Application
This Declaration applies to all versions of the Zelencio platform, including the Zelencio mobile application distributed through the Google Play Store, any web-based interface accessible via zelencio.com or associated domains, and any future distribution channel through which Zelencio services are made available. It applies to all users, whether registered or unregistered, who attempt to access the platform from any location worldwide.
1.3. User Acknowledgement of Jurisdictional Responsibility
By downloading, installing, accessing, or using the Zelencio platform in any capacity, you represent, warrant, and confirm that you are not located in, a citizen of, a tax resident of, or otherwise subject to the laws of any jurisdiction listed in this Declaration as restricted or prohibited. You further confirm that your use of the Zelencio platform does not violate any applicable law, regulation, or directive in your place of residence or domicile. Zelencio relies on this representation in good faith. Any user who provides false or misleading information regarding their jurisdiction of residence assumes full legal and financial responsibility for any consequences arising from such misrepresentation.
Section 2: Fully Restricted Jurisdictions
2.1. Definition of a Fully Restricted Jurisdiction
A Fully Restricted Jurisdiction is any country or territory in which Zelencio does not currently hold the required financial services license, virtual asset service provider registration, or cryptocurrency exchange authorization mandated by that jurisdiction's applicable laws and regulatory framework. Access to and use of the Zelencio platform, including account registration, asset deposits, trading, withdrawals, and all other features, is entirely prohibited for residents and citizens of Fully Restricted Jurisdictions.
2.2. List of Fully Restricted Jurisdictions
The following countries are designated as Fully Restricted Jurisdictions. Residents and citizens of these countries are prohibited from using the Zelencio platform in any capacity:
United States of America (USA) — Restricted under the requirements of the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Financial Crimes Enforcement Network (FinCEN), and applicable state-level money transmission licensing laws including the New York BitLicense framework.
United Kingdom (UK) — Restricted under the requirements of the Financial Conduct Authority (FCA), which mandates registration and authorization for all firms providing cryptoasset services to UK residents.
Canada — Restricted under the requirements of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and provincial securities regulators including the Ontario Securities Commission (OSC), which require registration as a Money Services Business and compliance with securities law for crypto trading platforms.
European Union Member States — Restricted under the requirements of the Markets in Crypto-Assets Regulation (MiCA) framework, Anti-Money Laundering Directives (AMLD), and applicable national financial authority requirements across all EU member states, including but not limited to Germany, France, the Netherlands, Italy, Spain, Sweden, Poland, and others.
United Arab Emirates (UAE) — Restricted under the requirements of the Virtual Assets Regulatory Authority (VARA) in Dubai and the Financial Services Regulatory Authority (FSRA) in the Abu Dhabi Global Market (ADGM), which require a Virtual Asset Service Provider license for operation.
Israel — Restricted under the requirements of the Israel Securities Authority (ISA) and applicable financial regulation governing digital asset platforms and trading services.
India — Restricted under the requirements of the Reserve Bank of India (RBI), the Securities and Exchange Board of India (SEBI), and evolving regulatory guidance governing virtual digital assets and crypto exchange services.
Australia — Restricted under the requirements of the Australian Securities and Investments Commission (ASIC) and the Australian Transaction Reports and Analysis Centre (AUSTRAC), which require an Australian Financial Services License and registration for digital currency exchange providers.
Singapore — Restricted under the requirements of the Monetary Authority of Singapore (MAS) and the Payment Services Act, which require a Digital Payment Token Service license for the provision of cryptocurrency exchange services.
Japan — Restricted under the requirements of the Financial Services Agency (FSA) of Japan, which requires registration as a Crypto Asset Exchange Service Provider.
South Korea — Restricted under the requirements of the Financial Intelligence Unit (FIU) of South Korea and the Act on Reporting and Using Specified Financial Transaction Information, which mandate Virtual Asset Service Provider registration.
Switzerland — Restricted under the requirements of the Swiss Financial Market Supervisory Authority (FINMA), which requires authorization for firms providing digital asset trading and custody services.
Hong Kong — Restricted under the requirements of the Securities and Futures Commission (SFC) of Hong Kong, which mandates licensing for virtual asset trading platforms under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).
New Zealand — Restricted under the requirements of the Financial Markets Authority (FMA) of New Zealand and the Financial Intelligence Unit, which require registration for firms providing digital asset services.
Saudi Arabia — Restricted under the requirements of the Saudi Central Bank (SAMA) and the Capital Market Authority (CMA), which prohibit or impose strict licensing requirements on virtual asset service providers.
Any country or territory designated as a High-Risk Jurisdiction by the Financial Action Task Force (FATF), including countries currently on the FATF Grey List or Black List, is subject to enhanced access restrictions and may be blocked from accessing specific features of the Zelencio platform without prior notice.
2.3. Updates to the Restricted Jurisdictions List
The regulatory landscape governing virtual assets and cryptocurrency exchanges is continuously evolving. Zelencio reserves the right to add, remove, or reclassify jurisdictions on this list at any time, without prior individual notice, in response to changes in applicable laws, regulatory guidance, or licensing requirements in any jurisdiction. The most current version of this Declaration will always be accessible on the Zelencio Policy Center. Users are responsible for reviewing this Declaration periodically for updates.
Section 3: Partially Restricted Jurisdictions
3.1. Definition of a Partially Restricted Jurisdiction
A Partially Restricted Jurisdiction is any country or territory where Zelencio's services are accessible but where specific features of the platform are unavailable, limited, or subject to enhanced compliance requirements due to local regulatory conditions. Users in Partially Restricted Jurisdictions may access the Zelencio platform for permitted activities but must acknowledge that certain features may be disabled or subject to additional verification requirements.
3.2. Current Partially Restricted Jurisdictions and Applicable Limitations
The following jurisdictions are designated as Partially Restricted. Users in these regions may register and access the platform but are subject to the specified feature limitations:
China (People's Republic of China) — Fiat-to-crypto conversion features, P2P trading involving Chinese Yuan (CNY), and marketing activities directed at Chinese residents are restricted. General platform access for non-CNY digital asset management may be available subject to continued monitoring of regulatory developments.
Iran — Access to Zelencio services is permitted subject to strict compliance with applicable international sanctions frameworks. Users in Iran are prohibited from conducting transactions that involve sanctioned entities, sanctioned assets, or that violate United Nations, United States OFAC, European Union, or United Kingdom sanctions programs, regardless of the user's location.
Russia — Access to Zelencio services is subject to ongoing monitoring in connection with international sanctions imposed following geopolitical developments. Transactions involving sanctioned Russian individuals, entities, or assets are strictly prohibited. Zelencio reserves the right to reclassify Russia as a Fully Restricted Jurisdiction at any time.
North Korea (Democratic People's Republic of Korea) — Access to Zelencio is currently fully prohibited due to international sanctions. North Korea is included in this section for reference but is treated in practice as a Fully Restricted Jurisdiction.
Cuba and Syria — Access is subject to OFAC sanctions compliance monitoring. Users must not be affiliated with sanctioned entities or use Zelencio to conduct transactions that would constitute a sanctions violation.
Section 4: Platform Enforcement and Technical Controls
4.1. Geo-Restriction Mechanisms
Zelencio employs a combination of technical and procedural controls to enforce jurisdictional restrictions. These controls include, but are not limited to, Internet Protocol (IP) address detection and geo-filtering at the point of access, device-level and network-level signals assessed during application launch and account registration, mandatory disclosure of jurisdiction of residence during the KYC identity verification process, and ongoing monitoring of user activity patterns for signals of jurisdictional misrepresentation.
4.2. Use of Virtual Private Networks (VPNs) and Circumvention Tools
The use of Virtual Private Networks (VPNs), proxy servers, Tor networks, or any other tool or technology designed to mask, alter, or falsify a user's actual geographic location for the purpose of bypassing Zelencio's jurisdictional restrictions is strictly prohibited. Any user found to have used circumvention tools to access the platform from a Restricted Jurisdiction will be subject to immediate account suspension, permanent termination without appeal, forfeiture of any pending transactions in accordance with applicable law, and reporting to relevant regulatory authorities where legally required.
4.3. Account Registration Declarations
During the account registration process, all users are required to declare their country of residence. This declaration is made under conditions that constitute a legal representation. Providing a false country of residence for the purpose of circumventing jurisdictional restrictions constitutes a material breach of the Zelencio Terms of Service and may constitute a criminal offence under the laws of the user's actual jurisdiction of residence.
Section 5: Regulatory Basis and Compliance Framework
5.1. Zelencio's Regulatory Position
Zelencio is a product of DMG Dynasty, a registered technology company. Zelencio operates as a Virtual Asset Service Provider (VASP) under a technology-first framework, providing software infrastructure for digital asset management. Zelencio does not currently hold financial services licenses in the Fully Restricted Jurisdictions listed in Section 2 of this Declaration. The platform's services are made available exclusively in jurisdictions where such services are either not subject to licensing requirements, are expressly permitted without a license for technology service providers, or where Zelencio has assessed that its services fall within an applicable regulatory exemption.
5.2. Target Markets
Zelencio's primary target markets are jurisdictions in sub-Saharan Africa and other emerging markets where the platform's services are accessible without a specific financial services license requirement for virtual asset service providers at the technology layer. These markets include, but are not limited to, Nigeria, Ghana, Kenya, Tanzania, Uganda, Rwanda, Zambia, Zimbabwe, Cameroon, Senegal, Ivory Coast, Ethiopia, and other jurisdictions across the African continent where digital asset services are accessible at the technology provider level.
Zelencio monitors regulatory developments in all of its target markets on an ongoing basis and will update its compliance posture, feature availability, and this Declaration as the regulatory environment in these markets evolves.
5.3. FATF Compliance Posture
Zelencio's AML and CTF compliance framework is designed in alignment with the Financial Action Task Force (FATF) Recommendations for Virtual Asset Service Providers, as detailed in the Zelencio AML and CTF Compliance Policy. Zelencio applies a risk-based approach to user verification, transaction monitoring, and jurisdictional access controls as part of this framework.
Section 6: Consequences of Unauthorized Access
6.1. Account Action for Restricted Jurisdiction Users
If Zelencio determines, at any time and through any means, that a user is accessing the platform from a Fully Restricted Jurisdiction, the following actions may be taken without prior notice: immediate suspension of the user's account and all associated transactions, initiation of an enhanced due diligence review, request for additional documentation to verify the user's true jurisdiction of residence, permanent termination of the account where the restriction is confirmed, and where legally required, reporting of the account to relevant regulatory authorities.
6.2. Fund Handling Upon Account Termination for Restricted Jurisdiction Violations
In the event that an account is terminated due to confirmed unauthorized access from a Restricted Jurisdiction, any digital assets held within the account will be subject to a mandatory review period. Following the completion of the review and subject to applicable laws, sanctions screening, and the absence of any legal hold or court order, Zelencio will make reasonable efforts to return verifiable assets to the user through a compliant withdrawal channel. Zelencio shall not be liable for any losses, delays, or costs incurred as a result of fund recovery processes arising from unauthorized jurisdictional access.
6.3. Legal Liability of the User
Users who access the Zelencio platform from a Restricted Jurisdiction assume full, sole, and complete legal and financial liability for any consequences arising from such unauthorized access, including but not limited to regulatory penalties, fines, legal proceedings, and asset forfeiture imposed by their local regulatory authorities. Zelencio expressly disclaims all liability in connection with a user's unauthorized access from a Restricted Jurisdiction.
Section 7: Contact and Compliance Inquiries
7.1. Jurisdictional Inquiries
Users or prospective users who have questions regarding the availability of Zelencio services in a specific jurisdiction, or who wish to seek clarification on the application of this Declaration to their circumstances, may direct their inquiry to the following official contact channels:
Support Email: help@zelencio.com
Official Help Center: help.zelencio.com
Legal and Compliance Portal: zelencio.com/help
Zelencio will make reasonable efforts to respond to jurisdictional inquiries within 5 business days. However, Zelencio's response to such an inquiry does not constitute legal advice, and users are strongly encouraged to seek independent legal counsel in their jurisdiction before accessing the platform.
7.2. Reporting of Suspected Violations
If you have reason to believe that another user is accessing the Zelencio platform from a Restricted Jurisdiction or is using circumvention tools to bypass jurisdictional controls, you may report this to Zelencio's compliance team at help@zelencio.com. All reports will be treated with confidentiality and reviewed by the Zelencio Trust and Safety team.