Sanctions Compliance Policy

Last Updated: July 16, 2026

1. Our Commitment

NoRug Labs (“we,” “our,” or “us”) is committed to complying with U.S. economic sanctions administered by the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury. As a U.S.-based software platform, we are required to ensure that our services are not used by sanctioned persons, entities, or jurisdictions.

2. Who We Screen

We screen users against the following U.S. sanctions lists:

Specially Designated Nationals (SDN) List — individuals and entities whose assets are blocked and with whom U.S. persons are generally prohibited from dealing
Foreign Sanctions Evaders (FSE) List — foreign persons who have violated, attempted to violate, or caused a violation of U.S. sanctions on Syria or Iran
Sectoral Sanctions Identifications (SSI) List — persons operating in sectors of the Russian economy subject to targeted sanctions

We also screen for connections to jurisdictions subject to comprehensive U.S. sanctions.

3. Restricted Jurisdictions

The Platform is not available to users located in, organized under the laws of, or ordinarily resident in:

Cuba
Iran
North Korea (Democratic People’s Republic of Korea)
Syria
The Crimea region of Ukraine
The so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine

This list is updated as U.S. sanctions programs evolve. We also reserve the right to restrict access from any jurisdiction where our legal counsel advises that Platform operation would create unacceptable regulatory risk.

4. How Screening Works

When you connect your wallet to the Platform:

Your wallet address is checked against our cached copy of the SDN and related sanctions lists.
Your IP address is checked for geolocation to determine whether you are connecting from a restricted jurisdiction.

If either check returns a match, access to the Platform is denied. We do not store your IP address after the geolocation check is complete. Screening results are logged for compliance purposes but are not shared with third parties except as required by law.

5. What Happens If You’re Flagged

If our screening identifies your wallet address or location as potentially subject to sanctions:

You will be unable to access the Platform.
You will see a notice explaining that access has been restricted due to sanctions screening.
If you believe the flag is an error, you may contact us at legal@noruglab.com with supporting documentation.

Important: NoRug Labs is a non-custodial software platform. We cannot freeze, seize, or control tokens on the blockchain. If a sanctioned person has already deployed a token before being flagged, our actions are limited to delisting from noruglab.com and disabling Platform interfaces for that token. The underlying smart contract and blockchain data remain publicly accessible and immutable.

6. Data Sources and Updates

Our sanctions screening data is sourced from official U.S. Treasury Department publications. We refresh our screening data regularly to reflect changes to U.S. sanctions programs. However, sanctions lists can change at any time, and we cannot guarantee that our screening data is current to the minute.

7. No Evasion

Users may not use VPNs, proxies, or other tools to circumvent geo-restrictions or sanctions screening. Attempting to evade sanctions controls is a violation of our Terms of Service and may itself be a violation of U.S. law. We reserve the right to terminate access for any user who attempts to circumvent our compliance measures.

8. Contact

For questions about this policy or to report a potential sanctions concern:

Email: legal@noruglab.com

This policy is part of our Terms of Service. NoRug Labs is a software company providing blockchain deployment tools. We are not a bank, exchange, money transmitter, broker-dealer, or investment advisor.