Jurisdiction & Limits Notice

BitLease Technologies Ltd. A subsidiary of 49G Holding Incorporated in Abu Dhabi Global Market (ADGM) ADGM Registration No.:34619

Last Updated: 21 March 2026

Effective Date: 21 March 2026

Version: 1.0

1. Platform Operator

The BitLease Platform is operated by BitLease Technologies Ltd., a company incorporated in Abu Dhabi Global Market (ADGM), United Arab Emirates, and a wholly owned subsidiary of 49G Holding. The Platform is governed by the laws of ADGM, and all LTO Contracts are subject to ADGM law with disputes resolved through the ADGM Arbitration Centre.

2. Service Availability

2.1 General Principle

BitLease’s services are made available to eligible users worldwide, subject to the jurisdictional boundaries set out in this Notice. Access to BitLease’s services in a particular jurisdiction depends upon BitLease’s ability to comply with the laws and regulations in such jurisdiction, the status of BitLease’s licensing efforts in such jurisdiction, the absence of any sanctions, and BitLease’s assessment of the legal, compliance, and operational risks associated with such jurisdiction.

2.2 No Universal Right of Access
Access to the Platform is not a universal right. BitLease reserves the right in its sole discretion to determine the jurisdictions in which it offers the services and to restrict, modify, or terminate access to the Platform in any jurisdiction at any time, with or without notice.

This Notice clearly outlines who is and who is not entitled to access the Platform and the basis upon which such determinations have been made, in an effort to eliminate any confusion regarding jurisdictional boundaries.

3. Prohibited Users: United States

3.1 Comprehensive US Exclusion

The Platform is not available to citizens, nationals, residents, or tax residents of the United States of America. This is a comprehensive, unconditional exclusion.

The following persons are prohibited from accessing, registering on, or using the Platform in any capacity:

3.2 Rationale

This exclusion is not arbitrary. It reflects the complexity and fragmentation of US federal and state laws and regulations relating to services involving digital assets, structured finance, and consumer financial products. US federal securities laws, including the Securities Act of 1933 and the Securities Exchange Act of 1934, US federal commodities laws, including the Commodity Exchange Act, US federal and state banking laws, and US federal and state money transmission laws, can all be extraterritorial in their reach. There exists a reasonable risk that the LTO model would be deemed to be a security under the Howey test, a commodity arrangement, or a consumer credit product under the US federal Truth in Lending Act and other US state laws, or a money services business. Moreover, there exists a reasonable risk that US federal sanctions imposed by the Office of Foreign Assets Control (“OFAC”) would also be extraterritorial in their reach, especially with regard to USD-denominated instruments such as stablecoins pegged to the value of the US Dollar. BitLease has determined it cannot ensure full compliance with all applicable US laws and regulations and, as such, cannot ensure the services would not expose BitLease and its users to material legal risk if it were to offer services to US persons.

3.3 No Exceptions
There are no exceptions to the US restriction. It applies to all Platform services, without limitation or distinction, and to the Client (Lessee) and Lessor (Capital Provider) roles. It applies to accredited investors, qualified purchasers, and institutional investors. It applies to US persons residing outside the US. It applies to dual citizens who hold US citizenship and citizenship in any other country. It applies to entities with any percentage of US ownership where a US person owns 10% or more of the entity or otherwise controls the entity.

4. Prohibited Users: Sanctioned Jurisdictions

4.1 Comprehensively Sanctioned Jurisdictions

The Platform is not available to persons located in, organized under the laws of, or ordinarily resident in jurisdictions subject to comprehensive international sanctions. As of the effective date:

This list is updated as sanctions designations change. The current list is maintained on the Platform.

4.2 Sectoral and Targeted Sanctions

In addition to fully sanctioned jurisdictions, BitLease will restrict access to any individuals or entities that appear on any of the applicable sanctions lists, including the OFAC SDN, EU Consolidated, UN Consolidated, UK HM Treasury, UAE National, as well as any ADGM-specific sanctions lists, regardless of where they are located. Entities that are 50% or more owned, individually or in aggregate, by a sanctioned party will also be restricted, which is in accordance with the "50% Rule" implemented by OFAC, as well as similar rules implemented in the EU, UN, and UK sanctions programs. These restrictions will also apply to individuals acting on behalf of, or for the benefit of, sanctioned parties or entities, as well as individuals located in jurisdictions subject to sectoral sanctions where the affected sectors include digital asset services, financial services, or technology services.

5. Additional Restricted Jurisdictions

5.1 Criteria

Beyond the United States and sanctioned jurisdictions, BitLease may restrict access from jurisdictions where additional risk factors are present:

1. Regulatory prohibition: Local law explicitly prohibits the provision or use of digital asset leasing services, structured crypto financing, or similar services;

2. Licensing gaps: BitLease has not obtained and cannot reasonably obtain the necessary regulatory authorization;

3. AML/CFT deficiency: The jurisdiction is listed on the FATF “black list” (High-Risk Jurisdictions Subject to a Call for Action) indicating strategic AML/CFT deficiencies;

4. Elevated risk: BitLease’s enterprise-wide risk assessment identifies the jurisdiction as presenting unacceptable compliance, legal, or operational risk;

5. Regulatory direction: A regulatory authority with jurisdiction over BitLease directs the restriction of services to a specific jurisdiction;

6. Operational infeasibility: BitLease cannot reliably verify identities, enforce contracts, or comply with local consumer protection requirements in the jurisdiction.

5.2 FATF Grey List Jurisdictions

Jurisdictions on the FATF “grey list” (Jurisdictions Under Increased Monitoring) are not automatically restricted, but users from these jurisdictions are subject to Enhanced Due Diligence (EDD) as described in the AML/CFT Policy. BitLease may impose additional restrictions (such as contract value limits or enhanced monitoring) for users from FATF grey-listed jurisdictions.

5.3 Current List

The current list of Additional Restricted Jurisdictions is maintained on the Platform at Bitlease.com and may be updated at any time without prior notice. Changes to the list take effect immediately upon publication.

6. Enforcement of Restrictions

6.1 Multi-Layer Enforcement

BitLease enforces jurisdictional restrictions through layered controls at every stage of the user lifecycle. No single control is relied upon in isolation. The layers work together so that a gap in one is covered by another.

At Registration:

Self-declaration of nationality, citizenship(s), country of residence, and tax residency. Attestation that the user is not a US person and is not located in a Restricted Jurisdiction. IP geolocation screening, with registration blocked from Restricted Jurisdiction IP addresses. Email domain and phone number analysis for US person indicators.

At Identity Verification (KYC):

Document-based verification of nationality and address. Detection of US-issued identification documents (US passport, US driver’s license, US state ID). Detection of US addresses, US tax identification numbers (SSN, ITIN, EIN), or US phone numbers. Sanctions screening against all applicable lists. Adverse media screening for jurisdiction-related risk.

During Active Use:

Continuous IP geolocation monitoring at login and during active sessions. Detection of VPN, proxy, Tor exit node, and other circumvention tool usage. Behavioral analysis comparing session IP patterns against declared residence. Device fingerprinting for consistency with declared location. Transaction-level sanctions screening at each LTO Contract execution, Buyout, Full Settlement, and significant LTO Wallet transaction. Blockchain analytics screening of incoming stablecoin deposits for connections to Restricted Jurisdiction wallets or sanctioned addresses.

Periodic Review:

Risk-based periodic re-verification of customer information. Daily batch re-screening against updated sanctions lists. Monitoring for changes in customer circumstances (e.g., relocation to a Restricted Jurisdiction).

6.2 VPN and Circumvention Detection

BitLease implements measures to detect and prevent circumvention of jurisdictional restrictions. These include commercial IP intelligence databases identifying known VPN, proxy, and Tor infrastructure; analysis of IP address consistency over time (sudden jurisdiction changes are flagged); device-level indicators inconsistent with declared location (timezone, language settings, keyboard layout); and comparison of multiple data points to detect mismatch patterns.

Detected circumvention attempts result in immediate session termination, the account being flagged for compliance review, potential account suspension pending investigation, and if confirmed, account termination and potential regulatory reporting.

6.3 False Declaration Consequences

If BitLease determines that a user has provided false information regarding their nationality, citizenship, residence, tax residency, or sanctioned status, the consequences are serious:

The account is immediately suspended. Active LTO Contracts are terminated through the standard termination process. Surplus Value is handled per the Terms of Service, subject to any legal hold or regulatory direction. The user may be permanently barred from the Platform. The incident is reported to the MLRO for STR/SAR evaluation. BitLease may report the matter to relevant authorities. BitLease also reserves the right to pursue legal remedies for breach of the Terms of Service.

7. Impact on Active Contracts

7.1 Existing Users Affected by New Restrictions

If a jurisdiction is added to the Restricted list while a user from that jurisdiction has an active LTO Contract, BitLease handles the transition with as much fairness as the circumstances allow:

1. BitLease will notify the affected user as soon as practicable;

2. The user will be given a reasonable wind-down period (minimum thirty (30) days unless a shorter period is required by law or sanctions) to settle their active contracts through Full Settlement or Buyout;

3. During the wind-down period, the user may not enter into new LTO Contracts;

4. If the user does not settle within the wind-down period, BitLease will terminate the contract through the standard process, with Surplus Value returned per the Terms of Service;

5. Non-recourse protection remains in effect throughout.

7.2 Sanctions-Related Freezes

If a user becomes subject to sanctions while having an active LTO Contract, the standard wind-down provisions do not apply. Instead:

1. All account activity is immediately frozen, with no transactions, Buyouts, settlements, or withdrawals.

2. The relevant sanctioning authority is notified.

3. Assets remain frozen until the authority provides instructions.

4. This overrides the standard wind-down provisions. There is no wind-down period for sanctions-related freezes.

5. Full details are described in the Sanctions & Prohibited Use Policy.

7.3 User Relocation

If an existing user relocates to a Restricted Jurisdiction:

1. The user is obligated to notify BitLease of the change in residence.

2. Upon notification or detection, the same wind-down provisions as Section 7.1 apply;

3. Failure to notify constitutes a breach of the Terms of Service and may result in immediate account termination.

8. User Responsibility

8.1 Compliance Obligation

Each user is solely responsible for ensuring that their access to and use of the Platform complies with all applicable laws and regulations in their jurisdiction of residence, citizenship, and tax residency. This includes determining whether the LTO model, digital asset ownership, stablecoin usage, and staking are lawful in their jurisdiction, understanding and complying with any local licensing, registration, reporting, or tax obligations that may apply to their use of the Platform, and seeking independent legal advice if uncertain about the legality of using the Platform from their jurisdiction.

BitLease provides the Platform. It does not provide jurisdiction-specific legal advice about whether you are permitted to use it.

8.2 BitLease’s Limitation

While BitLease implements jurisdictional restrictions to the best of its ability, it is not feasible to monitor and comply with every local law in every jurisdiction globally. The user’s own compliance obligation is independent of and supplementary to BitLease’s controls. The fact that BitLease has not blocked access from a particular jurisdiction does not constitute confirmation that use from that jurisdiction is lawful.

8.3 Indemnification

Users who access the Platform in violation of jurisdictional restrictions, including by providing false information about their nationality, residence, or tax status, agree to indemnify BitLease for any losses, claims, or regulatory penalties arising from such violation, as described in the Terms of Service.

9. Licensing and Regulatory Status by Jurisdiction

9.1 Current Licensing Applications

No license has been granted as of the effective date.

9.2 Implications for Users

Service availability in any jurisdiction is contingent upon successful licensing. BitLease may restrict services in jurisdictions where licensing has not been obtained. Users in jurisdictions where BitLease is not yet licensed use the Platform at their own risk regarding local regulatory compliance. BitLease will communicate material licensing developments that affect service availability.

10. Changes to Jurisdictional Restrictions

10.1 Updates

BitLease may update jurisdictional restrictions at any time based on changes in sanctions designations, changes in local laws or regulations, new licensing requirements or regulatory guidance, updates to the FATF grey or black list, changes in BitLease’s risk assessment, or regulatory directions from any competent authority.

10.2 Notification

When jurisdictions are added to the Restricted list, affected users are notified as described in Section 7.1. When jurisdictions are removed from the Restricted list, the change is published on the Platform, and no individual notification is required. Sanctions-related changes take effect immediately, and no prior notice is possible. The current Restricted Jurisdictions list is always available on the Platform.

11. Contact

For jurisdiction-related inquiries:

BitLease Technologies Ltd. A subsidiary of 49G Holding Incorporated in Abu Dhabi Global Market (ADGM) Registered Address: Unit PC-1, Level 7, Al Maryah Tower, Abu Dhabi Global Market Square, Abu Dhabi, Al Maryah Island, United Arab Emirates

ADGM Registration No.: 34619

Website: www.bitlease.com