Sanctions & Restricted Regions

Last updated: February 2026

Important: ChotkiSol is not available in certain countries and regions due to international sanctions regulations. Access from restricted jurisdictions is prohibited and will be blocked.

MidMightBit Games is committed to complying with all applicable international sanctions laws and regulations. As an Australian-based developer, we are subject to Australian autonomous sanctions as well as broader international sanctions regimes. ChotkiSol implements geographic screening to ensure compliance with these requirements.

1. Regulatory Framework

ChotkiSol's sanctions compliance programme is designed to meet the requirements of the following regulatory authorities and legal frameworks:

Authority	Full Name	Jurisdiction	Legal Basis
OFAC	Office of Foreign Assets Control	United States	International Emergency Economic Powers Act (IEEPA)
EU	European Union	European Union	EU Council Regulations
UN	United Nations Security Council	International	UN Charter Chapter VII
OFSI	Office of Financial Sanctions Implementation	United Kingdom	Sanctions and Anti-Money Laundering Act 2018
DFAT	Department of Foreign Affairs and Trade	Australia	Autonomous Sanctions Act 2011, Charter of the UN Act 1945

2. Restricted Jurisdictions

ChotkiSol is not available in the following countries and territories. Users located in, ordinarily resident in, or accessing the application from any of the following jurisdictions are prohibited from using ChotkiSol:

Country	ISO Code	Primary Sanctions Basis
Russia	RU	OFAC, EU, UK, AU
Belarus	BY	EU, UK, AU
North Korea	KP	OFAC, EU, UK, AU, UN
Iran	IR	OFAC, EU, UK, AU
Syria	SY	OFAC, EU, UK, AU
Cuba	CU	OFAC
Venezuela	VE	OFAC
Myanmar	MM	OFAC, EU, UK, AU
Sudan	SD	OFAC
South Sudan	SS	OFAC, EU, UK, AU, UN
Somalia	SO	OFAC, EU, UK, AU, UN
Libya	LY	OFAC, EU, UK, AU, UN
Central African Republic	CF	OFAC, EU, UK, UN
DR Congo	CD	OFAC, EU, UK, UN
Yemen	YE	OFAC, EU, UK, AU, UN
Zimbabwe	ZW	OFAC, EU
Nicaragua	NI	OFAC

This list reflects the current sanctions landscape as of February 2026. Additional Specially Designated Nationals (SDN) and sectoral sanctions may apply to individuals and entities not covered by country-level restrictions.

3. How Geographic Screening Works

ChotkiSol performs automated geographic screening at application launch to determine the user's country of location. The screening uses multiple signals, evaluated in the following priority order:

SIM Operator Country Code (Highest Priority) — The mobile country code (MCC) registered to the device's SIM card is used to determine the country associated with the user's mobile network operator. This is the most reliable indicator as it reflects the telecommunications registration of the device.
Network Operator Country Code — The country code of the network to which the device is currently connected. This may differ from the SIM operator when roaming internationally.
Device Locale — The country/region setting configured on the device by the user. While user-configurable, this provides a supplementary geographic signal.
Geocoder Reverse Lookup (If Permission Granted) — If the user has granted coarse location permission to the application, a reverse geocoding lookup is performed to determine the country at the device's approximate location. This uses Android's built-in Geocoder service and requires no network transmission of location data.

Screening Decision: If any of the above signals indicates that the user is located in a restricted jurisdiction, access to ChotkiSol will be blocked. The application applies a conservative approach — a match on any single signal is sufficient to trigger the restriction.

4. Privacy-Preserving Design

Your privacy is protected. All geographic screening is performed entirely on-device. No location data, country codes, or screening results are ever transmitted to any external server.

ChotkiSol's sanctions compliance screening is designed with privacy as a core principle:

On-device processing only — All country determination logic runs locally on the Seeker device. No data leaves the device during the screening process.
No data transmission — SIM operator codes, network codes, device locale, and location data are read by the application but are never sent to any server, API, analytics service, or third party.
No data storage — Geographic screening data is processed in memory during application launch and is not persisted to disk, databases, or shared preferences.
Coarse location only — If location permission is granted, the application requests only coarse (approximate) location, which provides city-level accuracy at most. Fine (GPS-precise) location is never requested or used.
Immediate disposal — Any location data obtained through the Geocoder reverse lookup is used solely for country-level determination and is immediately discarded after the check is complete.
No tracking — The application does not track, log, or record user locations over time. Each screening check is independent and stateless.

5. User Representations and Warranties

By downloading, installing, accessing, or using ChotkiSol, you represent and warrant that:

You are not located in, ordinarily resident in, or a citizen or national of any country or territory listed in the Restricted Jurisdictions table above.
You are not identified on any sanctions list, including but not limited to the OFAC Specially Designated Nationals and Blocked Persons List (SDN List), the EU Consolidated List of Persons, Groups and Entities Subject to Financial Sanctions, the UN Security Council Consolidated List, the UK HM Treasury Financial Sanctions List, or the Australian DFAT Consolidated List.
You are not acting on behalf of, or for the benefit of, any person, entity, government, or organisation that is the target of sanctions imposed by any of the authorities listed in the Regulatory Framework section above.
You are not owned or controlled (directly or indirectly, individually or in the aggregate) by any sanctioned person or entity.
You will not use ChotkiSol in any manner that would cause MidMightBit Games to violate any applicable sanctions laws, regulations, or orders.
You will not use any technical means (including but not limited to VPNs, proxy servers, Tor, or SIM spoofing) to circumvent the geographic screening mechanisms implemented by ChotkiSol.

6. Consequences of Violation

Warning: Attempting to access ChotkiSol from a restricted jurisdiction or in violation of sanctions regulations is a serious matter with potential legal consequences.

If ChotkiSol's geographic screening determines that a user is located in a restricted jurisdiction:

Access will be immediately blocked. The user will be unable to use the application's features and will be presented with a notice explaining that the application is not available in their region.
No workaround will be provided. MidMightBit Games will not provide any means to circumvent geographic restrictions.

If MidMightBit Games becomes aware that a user has accessed or is using ChotkiSol in violation of applicable sanctions laws or the user representations set forth above:

The user's access may be terminated without notice.
MidMightBit Games reserves the right to report suspected sanctions violations to the relevant authorities, including but not limited to DFAT (Australia), OFAC (United States), OFSI (United Kingdom), and any other applicable regulatory authority.
The user may be subject to civil and criminal penalties under applicable sanctions laws, which may include substantial fines and imprisonment.

7. Updates to Restricted Jurisdictions

International sanctions regimes are dynamic and subject to change. MidMightBit Games may update the list of restricted jurisdictions at any time, without prior notice, to reflect:

New sanctions imposed by any of the authorities listed in the Regulatory Framework section
Changes to existing sanctions programmes, including the addition or removal of countries, territories, or entities
Changes in the interpretation or enforcement of sanctions regulations
Guidance issued by regulatory authorities

Users are responsible for ensuring their continued compliance with all applicable sanctions laws. The most current version of this Sanctions & Restricted Regions policy will be available at this page. Continued use of ChotkiSol following any updates constitutes acceptance of the revised policy.

8. Disputed Territories

The restrictions applicable to countries listed in the Restricted Jurisdictions table extend to all territories occupied by, annexed by, or under the effective control of the governments of those countries. This includes, without limitation:

Crimea (occupied by Russia) — subject to OFAC, EU, UK, and AU sanctions
Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR) — subject to OFAC, EU, UK, and AU sanctions
Zaporizhzhia and Kherson oblasts (Russian-occupied areas) — subject to OFAC, EU, UK, and AU sanctions
Any other territory subject to comprehensive or territorial sanctions under applicable law

9. No Legal Advice

This Sanctions & Restricted Regions policy is provided for informational purposes only and does not constitute legal advice.

Sanctions law is complex, varies significantly across jurisdictions, and is subject to frequent change. This policy represents MidMightBit Games' good-faith effort to comply with applicable sanctions regulations but should not be relied upon as a comprehensive or authoritative statement of the law.

If you have any questions about whether sanctions restrictions apply to you, your organisation, or your intended use of ChotkiSol, you should consult with a qualified legal professional who specialises in international sanctions and export control law in your jurisdiction.

MidMightBit Games accepts no liability for any reliance placed on this policy as a substitute for professional legal advice.

10. Contact

If you have questions regarding this Sanctions & Restricted Regions policy, including questions about geographic screening, restricted jurisdictions, or compliance matters, please contact us:

MidMightBit Games
Melbourne, VIC, Australia
Email: aardappvark@proton.me