Karma Prohibited Activities List

I. Cardholder Prohibitions

A. Geographic Restrictions

Karma Cards cannot be issued to cardholders residing or registered in the following countries:

• Belarus
• China (Mainland)
• Cuba
• India
• Iran
• Iraq
• Israel
• Myanmar
• Nepal
• Nicaragua
• North Korea
• Russia
• Syria
• Turkey
• Ukraine
• Venezuela
• Vietnam

Karma does not support onboarding or card use in jurisdictions that present heightened legal, regulatory, or sanctions risks. Cardholders in countries listed on international watchlists (e.g., FATF Grey List) require case-by-case review and explicit approval from Karma's Compliance leadership.

B. Prohibited Business Types

Karma Cards cannot be issued to entities engaged in the following types of businesses under any circumstances:

C. Restricted Business Types (Subject to Enhanced Review)

Karma Cards may be issued to entities with the following business models, subject to enhanced review and approval requirements such as evidence of licensing, regulatory compliance, and strong internal controls:

• Money Service Businesses (MSBs) and remittance services
• Cryptocurrency platforms and exchanges
• Charities and non-governmental organizations (NGOs)
• Precious metals dealers
• Online content or creator platforms (e.g., subscription-based streaming or tipping)
• Regulated gambling or fantasy sports operations

II. Spending Prohibitions

A. Geographic Spending Restrictions

Karma Cards cannot be used for spending in the following countries:

• Cuba
• Iran
• North Korea
• Russia
• Syria
• Ukraine
• Venezuela

Card usage is prohibited in each of the countries listed above, regardless of whether the cardholder is an entity or an individual.

B. Prohibited Purchase Categories

Karma Cards cannot be used for any of the following types of purchases:

• Purchase or trade of digital currencies (other than through approved Karma services)
• Drug-related purchases, including marijuana, cannabis, CBD, and black-market items
• Payments on dark web marketplaces or for hacking/cybercrime services
• Internet pharmacies that are unlicensed or operate outside regulated jurisdictions
• Firearms, ammunition, or explosives
• Hazardous materials and chemicals without proper regulatory clearance
• Escort services or similar platforms
• Unlicensed or illegal auction sites
• Unregulated lending or payday loan services
• Data brokerage services, especially involving unauthorized personal data
• Purchase or trade of endangered species or wildlife products
• Pyramid schemes, multi-level marketing schemes, or Ponzi schemes
• Counterfeit goods or unauthorized replicas
• Illegal gambling operations or unregulated betting platforms
• Adult content or services that violate applicable laws

III. Sanctions Compliance

Karma strictly complies with all applicable sanctions programs, including but not limited to:

• UK Office of Financial Sanctions Implementation (OFSI)
• United States Office of Foreign Assets Control (OFAC)
• European Union Sanctions
• United Nations Security Council Sanctions
• Swiss State Secretariat for Economic Affairs (SECO) Sanctions

Users may not conduct transactions with individuals, entities, or countries subject to sanctions.

The Karma Wallet is non-custodial software. Karma cannot freeze, seize, move, or reverse assets held in a user's wallet, or reverse a transaction once it has been broadcast to a blockchain. Karma's sanctions controls act on access to Karma's software and on transactions before a user authorises them. Sanctions screening currently covers:

• Wallet screening for tokenised securities: before each purchase of tokenised securities (Ondo products), Karma screens the user's Ethereum wallet addresses against sanctions data using the Chainalysis Sanctions Oracle, and it rescreens the wallets of users with access to these products daily. If screening is unavailable, the purchase is refused.
• Partner screening: Bridge (virtual accounts, on-ramp and off-ramp) and Rain (Karma Card) screen their customers and transactions under their own compliance programmes, and execution venues screen the wallet addresses on the orders they receive.

Where Karma identifies a sanctions match or a sanctions risk, it may restrict the account's access to features of Karma's software, block or limit access to specific assets (for example, by allowing sales only or by blocking trading in an asset entirely), and report the matter to the relevant authorities where required by law. Bridge and Rain may independently restrict, suspend, or close the accounts and cards they provide, and decline or hold transactions on them, under their own terms. For more detail, see our Sanctions and Prohibited Jurisdictions Policy.

IV. Anti-Money Laundering (AML) Requirements

All Karma users must comply with applicable Anti-Money Laundering and Counter-Terrorist Financing regulations. The following activities are strictly prohibited:

• Structuring transactions to avoid reporting requirements
• Using Karma services to launder proceeds from illegal activities
• Funding or supporting terrorist organizations or activities
• Making false statements or providing false documentation during KYC processes
• Conducting transactions on behalf of sanctioned individuals or entities

V. Enforcement & Violations

Karma reserves the right to:

• Immediately suspend or terminate access to Karma's software and features for accounts engaging in prohibited activities
• Decline transactions in the Karma app before they are authorised, and block or limit access to specific assets (for example, by restricting an account to sell-only)
• Report violations to relevant law enforcement and regulatory authorities
• Pursue legal action against users who engage in prohibited activities

Users who violate this Prohibited Activities List may face permanent account termination and may be reported to authorities.

Because the Karma Wallet is non-custodial, Karma cannot freeze, reverse, or withhold assets held in a user's wallet. Our regulated partners (Bridge for fiat accounts and Rain for the Karma Card) may take action on the accounts, cards, and transactions they provide, including holding or declining transactions, under their own terms and legal obligations.

VI. Updates & Changes

Karma may update this Prohibited Activities List at any time to reflect changes in:

• Regulatory requirements and sanctions programs
• Risk assessment and compliance policies
• Geographic or business category restrictions
• Card network rules and requirements

Updates will be posted on this page with a revised "Last Updated" date. Continued use of Karma services constitutes acceptance of any updates to this list.

VII. Contact & Compliance Inquiries

If you have questions about whether a specific activity, business type, or transaction is permitted under this policy, please contact our Compliance team: