1. Introduction

This Geoblocker Policy outlines the measures adopted by Starbien Sp. z.o.o. (“Starbien”, “we”, or “the Company”) to restrict access to its services from jurisdictions considered high-risk or non-cooperative under international AML/CFT standards.

The Policy ensures compliance with:

• EU and EEA regulatory requirements.
• Recommendations of the Financial Action Task Force (FATF).
• Polish AML legislation.
• Other relevant international sanctions frameworks.

The purpose of this Policy is to protect the integrity of Starbien’s platform, prevent misuse of its services, and support the global fight against money laundering, terrorist financing, and sanctions evasion.

2. Geoblocking Overview

Starbien uses IP-based geolocation systems and related monitoring tools to detect and restrict access from prohibited regions.

Users are strictly prohibited from attempting to bypass these restrictions (for example, by using VPNs, proxy servers, or anonymization tools). Any such attempt may result in immediate account suspension and, where necessary, reporting to competent authorities.

This automated control prevents both account creation and service usage by individuals located in, or associated with, restricted jurisdictions.

3. Basis for Restrictions

Countries are restricted based on one or more of the following criteria:

• Classification by the European Union (EU), United Nations (UN), or FATF as high-risk, sanctioned, or non-cooperative jurisdictions.
• Presence on the EU financial sanctions list or OFAC sanctions list (U.S. Department of the Treasury).
• Active armed conflicts, civil instability, or occupation zones where financial controls cannot be verified.
• Local legislation that prohibits or restricts the operation of virtual asset services.

4. Restricted Countries and Territories

Starbien’s services are unavailable to individuals or entities located in or operating from the following jurisdictions:

In addition, Starbien restricts access from any regions under international sanctions, territorial disputes, or active occupation, including:

• Transnistria (Moldova)
• Abkhazia and South Ossetia (Georgia)
• Nagorno-Karabakh / Artsakh
• Western Sahara

This list is not exhaustive and may be expanded or modified at any time based on updates from international bodies, regulatory authorities, or the Company’s internal risk assessments. Full list is available in Internal AML procedure.

5. Policy Enforcement

Access attempts from restricted IP ranges are automatically blocked. Users detected to be accessing from a prohibited jurisdiction after registration will have their accounts suspended and transactions halted.

Funds associated with such activity may be frozen and reported in line with applicable AML/CFT obligations. Starbien reserves the right to request proof of residence or nationality at any time to verify compliance with this Policy.

6. Monitoring and Review

This Geoblocker Policy is reviewed periodically by Starbien’s Compliance Department and updated in line with:

• FATF, EU, and UN designations.
• Sanctions updates issued by the Polish Ministry of Finance or General Inspector of Financial Information (GIIF).
• Changes in Starbien’s business model or risk exposure.

All updates are published on the Starbien website and take effect immediately upon posting.

7. Contact Information

For questions or concerns regarding this Geoblocker Policy, contact:

Starbien Sp. z.o.o.
Email: support@startbien.com
Address: Plac Bankowy 2/1309, 00-095 Warsaw, Poland