Restricted Jurisdictions

iBTCY is not available in certain jurisdictions due to regulatory requirements and sanctions compliance.

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United States

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Definition of US Person

Under Regulation S of the US Securities Act of 1933, “US Person” includes:

• Any natural person resident in the United States
• Any partnership or corporation organized or incorporated under US laws
• Any estate of which any executor or administrator is a US person
• Any trust of which any trustee is a US person
• Any agency or branch of a foreign entity located in the United States
• Any non-discretionary account held for the benefit of a US person
• Any discretionary account held by a dealer organized in the United States
• Any partnership or corporation organized outside the United States by a US person principally for investing in unregistered securities

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Key Points

• No directed selling efforts are made in the United States
• iBTCY has not been and will not be registered under the US Securities Act of 1933
• Persons acting for the account or benefit of a US Person are also excluded

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British Virgin Islands

iBTCY is issued by SD Global Capital Limited, a BVI Business Company. However:

• This offering is not being made to persons in the British Virgin Islands
• Nothing in this documentation constitutes an offer to the public in the BVI
• The issuer does not solicit or accept subscriptions from BVI residents

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Sanctioned Jurisdictions

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Sanctions Screening

The issuer performs comprehensive sanctions screening:

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If You Become Sanctioned

If a holder of iBTCY or BTCY becomes subject to applicable sanctions: For iBTCY holders:

• Tokens may be frozen
• Redemption may be blocked
• The issuer retains full enforcement capabilities including compulsory redemption

For BTCY holders:

• You may continue to hold and transfer BTCY (transfers are permissionless)
• You cannot complete KYC verification
• You cannot unwrap BTCY to iBTCY
• You cannot access redemption proceeds

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Other Restricted Jurisdictions

The issuer may restrict additional jurisdictions at its discretion based on:

• Regulatory requirements
• Licensing obligations
• Risk assessment
• Changes in law

Any additional restrictions will be communicated to prospective investors during onboarding.

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Representations Required

Do not attempt to circumvent geographic restrictions using VPNs, proxies, or similar tools. Doing so may breach platform terms and trigger termination or compulsory redemption. All investors must represent and warrant that they:

1. Are not a US Person and are not acting for the account or benefit of a US Person
2. Are not located in or resident in the United States
3. Are not located in or resident in the British Virgin Islands
4. Are not located in or resident in any Sanctioned Jurisdiction
5. Are not subject to any sanctions administered by OFAC, UN, EU, or other relevant authorities
6. Will notify the issuer immediately if their status changes

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Consequences of Misrepresentation

Providing false information regarding jurisdiction or eligibility may result in:

• Immediate termination of the investment
• Forced redemption (if legally permissible)
• Reporting to relevant authorities
• Legal action for damages

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Compulsory redemption (summary)

The issuer may compulsorily redeem Notes in limited circumstances described in the Subscription Agreement (for example sanctions, compliance breaches, or where continued holding would violate law), generally with notice unless immediate action is required.

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Contact

For questions about jurisdiction eligibility: Email: [email protected]

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