Risk Appetite

Appetite And Restrictions On Nationalities And Residencies

Quickbyte Global OÜ has a clearly defined appetite for which countries and
nationalities it wishes to serve. The reason being the company has obligations
in order to fulfil its license as a VASP (Virtual Asset Service Provider). As
part of this we are obligated to uphold current sanctions regimes subject to the
country it operates from; Estonia. As such, Quickbyte Global OÜ ́s market
appetite is restricted to the European Economic Area (EEA
https://trade.ec.europa.eu/access-to-markets/en/content/european-economic-area-eea-agreement).

If any EEA country is put on any of the below sanctions and Risk-lists, the
listing will prevail, and our appetite will be adjusted accordingly until the
country is de-listed.

Exceptions: We are able to serve individuals who are nationals and residents of
countries identified as “low risk” and free of sanctions. However, this is only
on a case-by-case basis and is dependent on us approving the Enhanced Due
Diligence needed to accept and transact such clients.

For a full overview of relevant sanctions lists and countries, please see the
following lists and their reasoning:

– EU Sanctions

Reasoning: https://www.eeas.europa.eu/eeas/european-union-sanctions_en

Map: https://www.sanctionsmap.eu/#/main

– OFAC sanctions

List: https://ofac.treasury.gov/sanctions-programs-and-country-information

– UN sanctioned countries and people

Active UN sanctions: https://www.un.org/securitycouncil/sanctions/2653/materials

– FATF

High risk countries: https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html

“Black & Grey” list for AML/CTF: https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html