Prohibited Jurisdictions

This document forms part of the Company’s broader compliance framework and constitutes a schedule and addendum to, and forms part of the Wolfo Terms and Conditions of Use (the “Terms”). It supplements the Terms and, to the extent of any conflict, prevails over the Terms with respect to the subject matter of prohibited jurisdictions and related compliance obligations.

Foxo Development Corp. complies with all applicable Canadian laws, including reporting obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

For the purposes of this document, “Prohibited Jurisdictions” includes not only jurisdictions subject to applicable legal or regulatory prohibitions, but also jurisdictions that the Company restricts pursuant to its own risk-based compliance assessment.

Access to the Website and the services made available through it is not permitted for users located in, incorporated in, or otherwise connecting from any of the following jurisdictions:

• Afghanistan;
• American Samoa;
• Anguilla;
• Antigua and Barbuda;
• Barbados;
• Belarus;
• Burkina Faso;
• Cameroon;
• Cuba;
• Democratic Republic of the Congo;
• Democratic People`s Republic of Korea;
• Fiji Islands;
• Guam;
• Haiti;
• Iran;
• Iraq;
• Jamaica;
• Kenya;
• Lebanon;
• Libya;
• Mali;
• Mozambique;
• Myanmar;
• Namibia;
• Niger;
• Nigeria;
• Palau;
• Palestine;
• Panama;
• Philippines;
• Russia;
• Samoa;
• Senegal;
• Somalia;
• South Africa;
• South Sudan;
• Sudan;
• Syria1;
• Tanzania;
• Trinidad and Tobago;
• Uganda;
• US Virgin Islands;
• Vanuatu;
• Venezuela;
• Vietnam;
• Yemen; and
• Zimbabwe.

Syria¹ — Humanitarian exception: Following amendments to the Special Economic Measures (Syria) Regulations (SOR/2011-114, as amended February 13, 2026), specified activities and transactions aimed at the democratization and stabilization of Syria or the delivery of humanitarian assistance to or within Syria are authorised. This exception is narrow and does not affect the general access restriction applicable to the Syrian jurisdiction. The User must not use our platform in connection with any activities not covered by the amended Regulations. When in doubt, contact [email protected].

Foxo Development Corp. is registered with FINTRAC as a Money Services Business and is subject to Canadian anti-money laundering and sanctions legislation. Foxo Development Corp. complies with all applicable laws, regulations, and supervisory requirements and does not offer, market, or provide services to users located in, incorporated in, or otherwise connected to jurisdictions that are subject to Canadian sanctions, regulatory restrictions, or elevated financial crime risk beyond the Company’s defined risk appetite. Such restrictions are enforced through the Company’s onboarding, screening, and transaction monitoring processes and cannot be bypassed.

This list is based on, and maintained in accordance with, the following:

• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) – Canada’s primary AML/ATF legislation, which governs the obligations of Money Services Businesses including transaction monitoring, reporting, and client screening requirements;
• Special Economic Measures Act (SEMA) – authorizes the Government of Canada to impose targeted economic sanctions against foreign states, entities, and individuals;
• United Nations Act (UNA) – gives effect in Canadian law to binding UN Security Council resolutions, including sanctions, arms embargoes, and asset freezes;
• FINTRAC guidance – including guidance on high-risk jurisdictions and business relationships, and directives issued under the PCMLTFA;
• FATF assessments – the Financial Action Task Force periodically identifies jurisdictions with serious strategic deficiencies (“black list”) or under increased monitoring (“grey list”). We apply countermeasures to black-listed jurisdictions and conduct enhanced due diligence assessments for grey-listed jurisdictions as part of our risk-based compliance program; and
• he Company’s own risk-based compliance assessment, taking into account sanctions exposure, AML/CFT risk, fraud risk, regulatory risk, and the Company’s defined risk appetite.

Geographic restrictions form an integral part of the Foxo Development Corp. compliance framework and are applied in conjunction with broader AML/CFT and sanctions controls. In addition to restricting access from designated jurisdictions, the Company conducts comprehensive screening of all clients and relevant parties against applicable sanctions regimes to ensure that no services are provided to sanctioned individuals or entities. This screening process includes, but is not limited to:

• the Consolidated Canadian Autonomous Sanctions List maintained by Global Affairs Canada;
• OSFI’s Consolidated list of designated persons under the United Nations Suppression of Terrorism Regulations and related regulations; and
• applicable UN Security Council sanctions lists.

Access may be refused or suspended where the User, or any person on whose behalf they are acting, appears on any of these lists, regardless of the jurisdiction in which they are located.

To comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related regulations, Foxo Development Corp. applies enhanced due diligence to users who are identified as politically exposed persons (PEPs), heads of international organizations (HIOs), or family members or close associates of such persons. These measures may include additional identity verification, source of funds and source of wealth checks, enhanced ongoing monitoring, and other risk-based controls. As a result, Foxo Development Corp. may request additional information or documentation and may delay, restrict, or decline access to certain services.

Using a VPN, proxy, or any other technical means to bypass these restrictions is prohibited. We may suspend or terminate the User’s access if we believe the User is attempting to circumvent these controls.

Where required under the PCMLTFA and applicable sanctions legislation, Foxo Development Corp. may report relevant matters to FINTRAC or other competent authorities in accordance with its legal obligations.

This list is maintained on an ongoing basis and may be updated at any time without notice, in response to:

• changes to Canadian sanctions regimes under SEMA or the UNA;
• new or revised FINTRAC guidance or FATF assessments; or
• our own risk-based compliance assessments.

The most current version is always available on this page. We recommend that the User checks it regularly.

If a jurisdiction is added to this list after the User has been granted access to the Website, we reserve the right to suspend or terminate the User’s access immediately and without prior notice. We are not liable for any loss arising from such suspension or termination.

Quarterly review process: This list is reviewed at a minimum on a quarterly basis by the Compliance function of Foxo Development Corp. against the following sources:

• Active SEMA country-based sanctions regulations as published by Global Affairs Canada;
• Current UNA-implementing regulations and applicable UN Security Council resolutions;
• FATF high-risk jurisdictions (black list) and increased monitoring (grey list) publications, issued three times per year in February, June, and October;
• FINTRAC operational guidance on high-risk countries and business relationships; and
• the Company’s internal risk-based compliance assessment criteria and documented risk appetite.

The date of the most recent review and any resulting changes are documented in the Foxo Development Corp. internal compliance register. Any required updates to this list are implemented without delay following a compliance review. The next scheduled review will occur within 90 days of the most recent compliance review.

Jurisdiction classification note: Jurisdictions identified by the FATF as high-risk jurisdictions subject to a call for action are subject to access restriction as listed above. Jurisdictions identified by the FATF as jurisdictions under increased monitoring are not automatically restricted solely by virtue of that status. However, certain such jurisdictions may nonetheless be included in the Prohibited Jurisdictions list above where required by applicable sanctions, regulatory considerations, or the Company’s own risk-based compliance assessment. Users connected to other such jurisdictions may be subject to enhanced due diligence and may be refused or suspended access based on our risk assessment.

If the User believes access has been restricted in error, please contact us at [email protected].

We may ask the User to provide supporting documentation before reviewing the request.