Tab 1

Operational Countries

Prohibited Countries

Countries with Restrictions or Compliance Controls

Prohibited Industries

• Industries engaged in illegal activities or businesses that violate local, national or international laws or regulations.
• Industries or businesses involved in human rights violations, including those with documented history of child labor, forced labor or discriminatory practices.
• Businesses associated with unlicensed or unregulated gambling.
• Unlicensed or unregulated businesses.
• Industries that consistently engage in exploitative labour practices, including poor working conditions or lack of labour rights.
• Businesses that are involved in high-risk or controversial activities that do not fall within FiveWest’s risk appetite.

Tab 2

Operational Countries

FiveWest operates in, or may provide services to clients based in, the following countries, subject to applicable regulatory requirements, FiveWest’s compliance controls, risk appetite and any restrictions imposed by third-party service providers.

Primary Operational Countries

African Countries

Asian Countries

Prohibited Countries

Countries with Restrictions or Compliance Controls

Prohibited Industries

• Industries engaged in illegal activities or businesses that violate local, national or international laws or regulations.
• Industries or businesses involved in human rights violations, including those with documented history of child labor, forced labor or discriminatory practices.
• Businesses associated with unlicensed or unregulated gambling.
• Unlicensed or unregulated businesses.
• Industries that consistently engage in exploitative labour practices, including poor working conditions or lack of labour rights.
• Businesses that are involved in high-risk or controversial activities that do not fall within FiveWest’s risk appetite.

Tab 3

Operational Countries

FiveWest may provide services to clients based in or operating from the following jurisdictions, subject at all times to applicable legal and regulatory requirements, FiveWest’s internal compliance controls and risk appetite, sanctions screening, and any restrictions imposed by third-party service providers.

Primary Operational Countries

• Canada
• South Africa
• United Kingdom
• United States of America
• United Arab Emirates

African Countries

Asian and Middle Eastern Countries

Prohibited Countries

FiveWest will not onboard clients or provide services where the client, counterparty or relevant business activity involves the following jurisdictions:

Countries with Restrictions or Compliance Controls

Certain jurisdictions are not entirely prohibited but are subject to additional restrictions, enhanced compliance requirements or other onboarding controls.

• Russia*
• Zimbabwe

* FiveWest may onboard Russian individuals who are based in countries where FiveWest operates or has an existing client base, provided that the relevant country is not subject to applicable sanctions.

Any such onboarding remains subject to FiveWest’s internal compliance requirements and the approval or acceptance of relevant third-party service providers. For example, onboarding may be declined where FiveWest intends to onboard an individual in their personal capacity and a relevant liquidity provider, including Conduit, Binance or VALR, does not permit or approve the relationship.

FiveWest will not onboard any businesses registered in Russia.

Furthermore, where a business is registered in another accepted jurisdiction but has Russian ultimate beneficial owners (UBOs) who are majority shareholders and are not based in South Africa, FiveWest will not onboard such business.

All clients with a nexus to Russia or Zimbabwe may be subject to enhanced due diligence, additional source of funds and source of wealth verification, sanctions screening and any other controls considered appropriate by FiveWest’s Compliance Team.

Prohibited Industries

FiveWest will not onboard or provide services to businesses operating in, associated with or deriving a material portion of their activities from the following industries or activities:

• Industries engaged in illegal activities or businesses that violate applicable local, national or international laws or regulations.
• Industries or businesses involved in human rights violations, including those with a documented history of child labour, forced labour or discriminatory practices.
• Businesses associated with unlicensed or unregulated gambling activities.
• Unlicensed or unregulated businesses where a licence, registration, authorisation or regulatory approval is required by applicable law.
• Industries that consistently engage in exploitative labour practices, including poor working conditions or a lack of recognised labour rights.
• Businesses involved in high-risk, controversial or otherwise unacceptable activities that fall outside FiveWest’s risk appetite.

General Compliance Requirements

The inclusion of a country as an Operational Country does not constitute automatic approval of any client or transaction.

All prospective clients remain subject to FiveWest’s applicable KYC, KYB, AML/CFT, sanctions screening, adverse media screening and risk assessment procedures.

FiveWest may decline, restrict, suspend or terminate a client relationship where:

• the client or transaction falls outside FiveWest’s risk appetite;
• the client does not satisfy applicable onboarding or due diligence requirements;
• FiveWest is unable to obtain sufficient information regarding the client, its beneficial owners, source of funds, source of wealth or intended activities;
• a relevant bank, liquidity provider, payment service provider, custodian, exchange or other third-party service provider does not support the jurisdiction, client or activity;
• the relationship may expose FiveWest to unacceptable legal, regulatory, sanctions, financial crime, reputational or operational risk; or
• FiveWest determines that providing services would otherwise be inappropriate.

FiveWest reserves the right to amend its list of Operational Countries, Prohibited Countries, restricted jurisdictions and Prohibited Industries from time to time in response to changes in applicable law, sanctions regimes, regulatory guidance, third-party requirements or FiveWest’s risk appetite.