Acceptable Use Policy

Version: 1.0 · Last updated: 2026-08-30 · Effective date: 2026-09-01

This policy forms part of our Terms of Service. Words defined there have the same meaning here.

1. Who may use the Service

By opening an account and by every use of the Service you confirm that:

1. You are not, and are not acting for or on behalf of, a person or entity that is subject to sanctions, an asset freeze, or a targeted restrictive measure under the sanctions regimes listed in §2.
2. You are not owned as to 50 per cent or more, or controlled, directly or indirectly, individually or in aggregate, by such a person or entity.
3. You are not located in, ordinarily resident in, or established in a restricted jurisdiction (§2.2), and you will not use the Service from one.
4. The TRON addresses you nominate — as an order sender or recipient, or in an auto-refill rule — are not associated with sanctioned persons, and you are authorised to have Energy delivered to them.
5. The funds you use to purchase Service Credits are lawfully yours and are not the proceeds of crime.

These confirmations are given each time you use the Service, not only when you sign up. If any of them stops being true, stop using the Service and tell us.

2. Sanctions

2.1 Regimes we apply

We apply the following, and this policy means all of them wherever it says "sanctions":

• European Union restrictive measures, and United Nations Security Council measures as implemented in the EU. As a company established in Cyprus we are bound by these directly, and we apply them as law.
• United States OFAC measures — the Specially Designated Nationals list, including its published digital currency addresses — and United Kingdom OFSI measures. These lists do not, in general, bind a Cyprus company as law, and we apply them as a risk control: our infrastructure and suppliers have US and UK exposure, and an address designated on those lists is not one we are willing to serve. A match against them is handled the same way as a match against the lists that bind us (§2.4).

2.2 Restricted jurisdictions

The restricted jurisdictions are, in full:

• the Islamic Republic of Iran;
• the Democratic People's Republic of Korea (North Korea);
• the Syrian Arab Republic;
• the Republic of Cuba;
• the Russian Federation;
• the Republic of Belarus;
• the temporarily occupied territories of Ukraine: Crimea and Sevastopol, and the areas of the Donetsk, Luhansk, Zaporizhzhia and Kherson regions not controlled by the Government of Ukraine.

The restriction is total for every entry: no accounts, no orders, no auto-refill rules, no access. The list reflects comprehensive embargo regimes and the EU prohibitions on providing crypto-asset services to persons in Russia and Belarus. We review it quarterly, and immediately on a major change in the underlying regimes; the review date is the "Last updated" date above.

Access from a restricted jurisdiction may be blocked on the basis of the IP address we see. That check is a control, not a determination: it can be evaded and it can be wrong. Evading it is itself a breach of this policy.

2.3 Screening

We screen incoming transfers to deposit addresses against published sanctions lists of digital currency addresses, and we may screen the addresses you nominate in orders and auto-refill rules. Screening is automated, is imperfect, and is not a guarantee that any address or counterparty is clean. It is our control, not a service to you, and no result of it is advice you may rely on.

Our screening is separate from, and additional to, the USDT token contract's own blacklist. We refuse orders for recipients on that blacklist because such a transfer would fail anyway; that check has nothing to do with sanctions.

2.4 What happens on a match

If a screening match arises on your account or on a transfer to your deposit address:

1. We freeze the account. New orders are refused, auto-refill rules stop spending, and incoming transfers are not credited.
2. We do not return anything automatically. Funds associated with a match are not credited and are not sent back. Returning value to an address associated with a sanctioned person could itself be a breach, and a decision of that kind is not one an automated system may take.
3. A person reviews it. Screening produces false positives; a human decides what the match actually is.
4. We report where we are required to. In Cyprus, frozen assets and screening matches are reported without delay to the national sanctions implementation authority, and suspicious activity to MOKAS, the Cyprus financial intelligence unit. We may be prohibited by law from telling you that a report has been made, or from telling you why an account is frozen.
5. Release, if any, follows the applicable requirements. Where a match is cleared, we unfreeze the account and process the transfer normally. Where it is not, the position stays as it is until we are permitted or required to do something else with it.

What we can tell you. That the account is frozen and that the freeze follows from a compliance obligation. We will not tell you which list matched, what was reported, or to whom; where the law prohibits even the fact of a report from being disclosed, we comply with that.

3. Prohibited use

You must not use the Service:

1. to launder money, to conceal the origin of funds, or to finance terrorism or proliferation;
2. to move, or to facilitate the movement of, the proceeds of crime;
3. to evade sanctions, export controls, or any other restriction — including by using intermediary addresses, nominee accounts, VPNs or other means to misrepresent your location or identity;
4. to interact with addresses you know or reasonably suspect to be associated with sanctioned persons, ransomware, darknet markets, theft, fraud, or the exploit of a protocol or bridge;
5. to support fraud, market manipulation, phishing, or the sale of stolen data or credentials;
6. on behalf of another person while concealing that fact, where the purpose or effect is to obscure who is really behind the activity. Serving your own clients through the Service is not, by itself, a breach — see item 9; the breach is misrepresentation, a nominee arrangement designed to defeat screening, or lending your account to a person who could not open one;
7. in a way that breaches any law applicable to you or to us;
8. to attack, overload or degrade the Service: circumventing rate limits or authentication, probing for vulnerabilities without permission, scraping at a volume that affects other customers, or using automation to create multiple accounts;
9. to resell or wrap the Service while presenting your customers as ours. Building on the Service is welcome — you may integrate it into your own product and serve your own customers through it — but you remain our only counterparty, you are responsible for everything your integration submits as if you had submitted it yourself, and your customers acquire no rights against us;
10. to attempt to obtain Service Credits without paying for them, including by exploiting a defect in pricing, recognition or reconciliation. If you find such a defect, tell us.

4. Responsible disclosure

If you find a security vulnerability, report it to security [at] nrg.market and give us a reasonable time to fix it before disclosing it. Do not access other customers' data, do not degrade the Service, and do not extract more data than is needed to demonstrate the issue. We will not pursue a researcher who acts on that basis. We do not currently offer a bug bounty.

5. Enforcement

We may, without prior notice and at our discretion:

• refuse an individual order, transfer, or auto-refill rule;
• rate-limit, restrict, suspend, or freeze an account;
• withhold crediting of an incoming transfer;
• terminate an account and the agreement;
• report to the authorities where we are required to, or where we reasonably believe an offence has been committed.

We choose the response proportionate to the circumstances, but a sanctions match always results in a freeze pending review (§2.4).

Effect on your balance. A freeze does not forfeit Service Credits, and it is not a penalty; it stops movement while the position is reviewed. Where an account is terminated for breach of this policy, any remaining balance is treated under the Terms of Service §13.3 — unused Service Credits are forfeited on closure — subject to the legal requirements that apply, which may in any case prohibit returning it. A closure we initiate for breach comes with no spend-down period; the Terms distinguish a termination for cause from an ordinary one on exactly this point (Terms §13.5).

6. Reporting misuse

If you believe the Service is being misused, write to abuse [at] nrg.market with enough detail for us to investigate.

7. Changes

We may change this policy; the Terms of Service govern how changes take effect. The sanctions lists and restricted jurisdictions referred to in §2 change on their own schedule and apply as they stand from time to time, without a change to this document.