Sanctions Policy

Effective: 7 August 2026

CitizenSol complies with international sanctions regulations. This policy describes how the App implements regional restrictions to ensure compliance.

1. Regulatory Compliance

CitizenSol is designed to comply with sanctions and export control regulations administered by the following authorities:

• OFAC — United States Office of Foreign Assets Control (U.S. Department of the Treasury)
• EU — European Union Common Foreign and Security Policy sanctions
• UK OFSI — United Kingdom Office of Financial Sanctions Implementation (HM Treasury)
• UN — United Nations Security Council sanctions
• Australian DFAT — Australian Department of Foreign Affairs and Trade sanctions

2. Restricted Regions

The App is not available for use in the following 29 countries. Users detected as being in these countries will be unable to access App functionality. This list exactly matches the block list implemented in the App.

Sanctioned Countries (21)

• Afghanistan (AF)
• Belarus (BY)
• Central African Republic (CF)
• Cuba (CU)
• Democratic Republic of the Congo (CD)
• Haiti (HT)
• Iran (IR)
• Lebanon (LB)
• Libya (LY)
• Mali (ML)
• Myanmar / Burma (MM)
• Nicaragua (NI)
• North Korea / DPRK (KP)
• Russia (RU)
• Somalia (SO)
• South Sudan (SS)
• Sudan (SD)
• Syria (SY)
• Venezuela (VE)
• Yemen (YE)
• Zimbabwe (ZW)

Additional Restricted Countries (8)

• Bosnia and Herzegovina (BA)
• Burundi (BI)
• Chad (TD)
• Eritrea (ER)
• Guinea (GN)
• Guinea-Bissau (GW)
• Iraq (IQ)
• Ukraine (UA)

Note on Ukraine: the App's country-level detection cannot distinguish specific occupied or disputed territories (Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia, Sevastopol), so the restriction is applied to Ukraine (UA) as a whole.

3. Detection Method

Regional detection is performed entirely on-device using multiple signals to determine the user's likely location. The App checks the following device-level indicators:

• SIM country code — the country code of the installed SIM card (MCC)
• Network country code — the country reported by the mobile network operator
• Device locale — the language and region settings configured on the device
• Timezone — the device's configured timezone

If any of these signals indicate a restricted region, the App will display a compliance notice and restrict access.

4. Privacy-Preserving Approach

Our sanctions compliance implementation is designed to protect user privacy:

• All checks are performed locally on the device
• No location data is transmitted to any server
• No GPS or precise location is used
• No location data is stored or logged
• No user data is collected as part of the compliance check
• The check runs only at app startup

5. Circumvention

Users are prohibited from using VPNs, proxy servers, SIM spoofing, or any other technical means to circumvent regional restrictions. Attempting to bypass sanctions compliance features may violate applicable laws in your jurisdiction.

6. Updates

The list of restricted regions may be updated in future versions of the App to reflect changes in international sanctions programs. We will update this policy accordingly.

7. Contact

If you believe you are seeing a restriction in error, or have questions about this Sanctions Policy, contact us at:

aardappvark@proton.me

MidMightBit Games
Melbourne, VIC, Australia