Magnitude Markets Restricted Persons and Jurisdictions Policy

This Restricted Persons and Jurisdictions Policy (the “Policy”) forms part of the Magnitude Markets Mainnet Terms of Use (the “Terms”). Capitalised terms not defined in this Policy have the meanings given in the Terms.

Risk-bearing features of the Interface are not offered to, and may not be accessed or used by, a Restricted Person. Magnitude may restrict other Interface features where required by Applicable Law or this Policy. This Policy governs the Magnitude frontend and the routes and actions Magnitude controls. It does not purport to control Hyperliquid, a public blockchain or a person's independent access to third-party infrastructure.

Restrictions may apply differently to viewing information, creating an Account, connecting a Wallet, depositing collateral, opening or increasing a position, cancelling an order, reducing or closing a position, withdrawing, participating in a Programme, or using another feature. An External Market Provider may impose separate restrictions under the External Market Terms identified or linked on the relevant Market page. Eligibility to use the Interface does not establish eligibility to use an externally provided Market.

1. Restricted Person

A “Restricted Person” means any of the following:

1. a U.S. Person;
2. a person physically located, ordinarily resident or domiciled in a Restricted Jurisdiction;
3. an entity incorporated, organised, established or registered in a Restricted Jurisdiction, or having its registered office, principal place of business or substantial operations there;
4. a person who is the subject or target of an asset freeze, blocking restriction, denial order, prohibition, designation or other economic, trade or financial sanction administered or enforced by a Sanctions Authority applicable to Magnitude, its providers or the relevant activity;
5. an entity owned or controlled by one or more sanctioned persons to the extent the applicable Sanctions Laws restrict that entity, including an entity owned 50% or more in the aggregate by blocked persons where the applicable rule uses that threshold;
6. a person acting on behalf of, at the direction of, or for the account or benefit of a person described above;
7. a government, public body, state-owned entity, political organisation or public official where access would violate Applicable Law or create a prohibited sanctions, bribery or corruption risk;
8. a person whose access is prohibited by a court order, regulatory direction, licence condition, professional duty, employer restriction or other binding requirement;
9. a person who has provided inaccurate or misleading identity, location, residence, incorporation, ownership, control or eligibility information;
10. a person who has attempted to evade screening or circumvent an access restriction; or
11. a person whose access to or use of the Interface would violate Applicable Law or cause Magnitude, an affiliate, a service provider, the Protocol or another person to violate Applicable Law.

A person is not automatically a Restricted Person merely because a screening provider assigns a risk score or identifies indirect exposure. Magnitude may nevertheless pause new risk and conduct a review while it resolves that information.

2. U.S. Person

For this Policy, a “U.S. Person” means:

1. a citizen or national of the United States;
2. a natural person resident or ordinarily resident in the United States;
3. an entity, partnership, corporation, limited liability company, association, trust, fund or other legal arrangement incorporated, organised, established or registered under the laws of the United States or any political subdivision of it;
4. an estate whose executor or administrator is a U.S. Person;
5. a trust for which a trustee is a U.S. Person;
6. an agency, branch, office or other establishment located in the United States; or
7. an Account, Wallet or legal arrangement held for the account or benefit of a person described above.

The “United States” includes its states, the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, American Samoa, the Northern Mariana Islands, and every other territory or possession of the United States.

This is a contractual definition used for Magnitude's eligibility policy. It is not a representation that one definition reproduces every U.S. statute or regulation.

3. Restricted Jurisdictions Schedule

For purposes of this Policy, a “Restricted Jurisdiction” means a jurisdiction identified in Section 3.1 or 3.2, or made subject to an additional restriction under Section 3.1. The restriction may apply to a particular Market, person or action, or to the entire Interface, as stated in the applicable access decision.

The following schedule applies from the Effective Date.

3.1 Product and regulatory exclusions

Persons located, resident, domiciled, incorporated, organised, established or registered in the following jurisdictions may not open or increase a position or otherwise use a risk-bearing trading feature:

1. United States, including all states, the District of Columbia and U.S. territories and possessions;
2. United Kingdom, including England, Scotland, Wales and Northern Ireland;
3. Canada, including every province and territory.

Magnitude may apply an additional restriction to a particular Market, category of user, jurisdiction or action where required by Applicable Law, a regulator, a court, the Protocol or a material service provider, or where Magnitude does not hold a required licence, registration, authorisation, approval or permission.

Omission from this schedule does not represent that access or trading is lawful in a jurisdiction, does not guarantee that Magnitude will make a Market or action available there, and does not replace a user's responsibility to comply with Applicable Law.

3.2 Sanctions-based territorial restrictions

Access is also prohibited from any country, territory or region subject to a comprehensive or substantially comprehensive territorial prohibition applicable to Magnitude, its providers or the relevant activity.

As of the Last Updated date, the public schedule includes:

1. Cuba;
2. Iran;
3. North Korea;
4. the Crimea region of Ukraine;
5. the areas of the Donetsk and Luhansk regions of Ukraine covered by applicable territorial sanctions; and
6. any other country, territory or region that becomes subject to an applicable comprehensive territorial prohibition.

Territorial sanctions can apply below country level and can change without notice. Magnitude may use regional, postal, mapping and other location information where a country code alone is not sufficient.

3.3 Named persons and ownership or control

This Policy also restricts persons and entities identified under applicable sanctions and export-control regimes, including applicable lists maintained by:

• the Government of Singapore and Monetary Authority of Singapore;
• the United Nations Security Council;
• the U.S. Department of the Treasury's Office of Foreign Assets Control, U.S. Department of State and U.S. Department of Commerce;
• the United Kingdom government, including the current UK Sanctions List;
• the European Union and competent authorities of its member states; and
• any other Sanctions Authority applicable to Magnitude, its providers or the relevant activity.

Sanctions regimes use different ownership and control tests. Magnitude applies the rule relevant to the applicable regime and does not assume that one regime's threshold determines the result under every other regime.

Published blockchain addresses are not exhaustive. Magnitude may consider identity, ownership, control, Account, Wallet, counterparty, beneficiary and transaction information in addition to exact-address matches.

4. No Indirect Access

You must not access or use the Interface for the account or benefit of a Restricted Person or enable a Restricted Person to access or use it.

You must not act as an agent, nominee, trustee, intermediary, custodian, representative, signatory, authorised trader, Wallet delegate, API user or other person for a Restricted Person in connection with the Interface.

No beneficial owner, controller, Account holder, Wallet owner, principal or beneficiary connected with your use may be a Restricted Person.

You must not share an Account, Wallet, session, credential, API key, signing authority, agent authorisation, referral code or trading authority with a Restricted Person.

5. No Circumvention or Concealment

You must not use or attempt to use any of the following to evade screening, obtain access or circumvent a restriction:

1. a VPN, proxy, Tor exit node, relay, private relay, remote desktop, remote host, cloud-hosted device, location-spoofing service or similar technology;
2. false, borrowed, altered, misleading or incomplete identity, address, residence, nationality, corporate, ownership or other information;
3. another person's Account, Wallet, device, credential, identity or access right;
4. a chain of agents, beneficiaries, subaccounts, Wallets or entities intended to obscure ownership or control; or
5. another method intended to conceal or misstate your identity, location, residence, nationality, incorporation, ownership, control, source of access or eligibility.

Using privacy or security technology for a legitimate purpose does not permit access by a Restricted Person or from a Restricted Jurisdiction.

A VPN, proxy, hosting, relay or device signal can be incomplete or wrong. Magnitude may request additional information, permit an appeal or apply a temporary restriction while resolving conflicting signals.

6. Ongoing Representations

Each time you access the Interface, create or use an Account, connect or authorise a Wallet, approve an agent or Builder Fee, deposit collateral, participate in a Programme, or submit, modify or cancel an instruction, you represent and warrant that:

1. you satisfy the eligibility requirements in the Terms;
2. you are not a Restricted Person;
3. no person for whom you act and no beneficial owner, controller, principal, beneficiary, Account holder or Wallet owner connected with your use is a Restricted Person;
4. you are not located in or accessing the Interface from a Restricted Jurisdiction;
5. all eligibility information you provide or make available is complete, accurate and not misleading;
6. you are not concealing your identity or location or circumventing a restriction;
7. your access and activity are lawful; and
8. your access and activity will not cause Magnitude or another person to violate Applicable Law.

If a representation ceases to be accurate, you must not deposit additional collateral, open a new position, increase risk or enter a new Programme. You must use only the lawful recovery functionality made available to you and contact legal@magnitude.markets if assistance is required.

7. Geoblocking, Screening and Verification

Magnitude may use IP-derived location, VPN, proxy, Tor, relay and hosting indicators, device and session signals, Account and Wallet information, public blockchain data, sanctions and fraud data, and identity or location verification to enforce this Policy.

Geoblocking applies to the Interface and access points Magnitude controls. It does not represent that Magnitude controls or can prevent independent access to a public blockchain or third-party protocol.

These signals may be incomplete or incorrect. Magnitude may request additional information or review conflicting information before making an access decision. If location or eligibility cannot be reliably determined, new or increased risk may be unavailable.

Magnitude is not required to disclose confidential screening thresholds or methods where disclosure could facilitate circumvention, prejudice an investigation, weaken security or violate law or another person's rights.

8. Frontend Access Restrictions

Magnitude may allow, limit, require verification for, make read-only or close-only, or deny access to all or part of the Interface.

Magnitude does not custody assets merely by providing the Interface and cannot use this Policy to block or freeze assets, alter the Protocol, or prevent independent access to public blockchain infrastructure. The Protocol or an External Market Provider may separately determine whether an instruction can be executed and how a Market, position, resolution, settlement or recovery process operates.

Where permitted by law and supported by the Protocol or External Market Provider, read-only or close-only functionality may be available. Magnitude does not guarantee access to any recovery action it does not control. A sanctions requirement, court order or other binding direction may require a different outcome.

9. Reviews and Appeals

If access is restricted and a review is legally permitted, you may contact legal@magnitude.markets.

Your request should include:

• the case or decision identifier displayed by the Interface;
• the affected Account or public Wallet address;
• a description of the issue; and
• only the minimum information reasonably necessary to resolve it.

Do not send a private key or seed phrase.

Magnitude may request evidence of location, residence, incorporation, ownership, authority, professional status or another relevant fact. A review does not guarantee access.

Magnitude may withhold details concerning a screening method, sanctions report, investigation or confidential third-party information.

10. Changes to This Policy

Sanctions lists, territorial measures, product laws, licensing requirements and Magnitude's permitted markets may change.

Magnitude may update this Policy and the Restricted Jurisdictions Schedule. The current version and effective date are shown above. A restriction required by Applicable Law, a regulator, a Sanctions Authority, a court, the Protocol or a critical service provider may take effect immediately.

If an update makes you a Restricted Person, you must stop opening or increasing risk and use only the lawful recovery functionality made available to you.

11. Contact

Questions and access-review requests may be sent to:

legal@magnitude.markets

Do not send private keys, seed phrases or unnecessary identity documents by ordinary email.