Compliance Policy
Preamble
This Compliance Policy ("Policy") governs Wagyu's ("Wagyu," "we," "our") procedures with respect to the handling, restriction, blacklisting, and potential seizure of user assets.
Wagyu's approach to asset restriction is modelled on the compliance framework publicly established and applied by Circle Internet Financial, LLC ("Circle") with respect to USD Coin (USDC). As Circle CEO Jeremy Allaire stated publicly in April 2026:
"Circle has a very, very clear performance obligation under the law. Circle follows the rule of law, and we are able to undertake actions such as freezing a wallet at the direction of law enforcement or the courts."
Wagyu adopts this standard. Wagyu will not freeze or seize User Assets on the basis of informal requests, voluntary referrals, or non-binding communications from any party in the absence of a binding court order.
1. Applicable Laws and Regulations
Your use of Wagyu and any Assets transacted through it is subject to the laws, regulations, and rules of any applicable governmental or regulatory authority, including without limitation all applicable tax, anti-money laundering ("AML") and counter-terrorist financing ("CTF") provisions and sanctions. You agree to act in compliance with and be legally bound by this Policy and all applicable laws and regulations. This Policy is conditional on your continued compliance at all times with its terms and all applicable laws and regulations.
Applicable laws require Wagyu to prevent Restricted Persons from accessing or using Wagyu's services. A Restricted Person means any person that is the subject or target of any sanctions, including a person that is:
(a) named in any sanctions-related list maintained by the U.S. Department of State; the U.S. Department of Commerce, including the Bureau of Industry and Security's Entity List and Denied Persons List; or the U.S. Department of the Treasury, including the OFAC Specially Designated Nationals and Blocked Persons List, the Sectoral Sanctions Identifications List, and the Foreign Sanctions Evaders List; or any similar list maintained by any other relevant governmental authority;
(b) located, organised, or resident in a country, territory, or geographical region that is itself the subject or target of any territory-wide sanctions (a "Restricted Territory"), including without limitation Cuba, Iran, North Korea, and the Ukrainian regions of Crimea, Donetsk, Luhansk, Kherson, and Zaporizhzhia; or
(c) owned or controlled by any person or persons described in (a) or (b) above.
2. Eligibility
By accessing or using Wagyu, you represent and warrant that:
(a) you are at least 18 years of age, are not a Restricted Person, and are not accessing Wagyu on behalf of a Restricted Person;
(b) you will not use Wagyu for any illegal activity, including without limitation illegal gambling, money laundering, fraud, blackmail, extortion, ransoming data, terrorist financing, or any other violent or prohibited activity, including those listed under Section 4 of this Policy;
(c) all information you provide in connection with your use of Wagyu is accurate, current, and complete; and
(d) your use of Wagyu does not violate any applicable law or regulation.
If Wagyu suspects or determines that you have violated this Policy, including by attempting to transact with or through Blocked Addresses or by engaging in Prohibited Transactions, Wagyu reserves the right to block your address from further interaction with Wagyu. Any freeze or seizure of Assets remains subject to the requirements of Section 5(a) of this Policy.
3. AML and CTF Compliance
Wagyu's AML and CTF procedures are guided by all applicable laws and regulations regarding anti-money laundering and counter-terrorist financing. These standards are designed to prevent the use of Wagyu for money laundering, terrorist financing, or any other financial crime.
4. Prohibited Transactions
Use of Wagyu for transactions related to any of the following is prohibited. Wagyu reserves the right to monitor and, where appropriate, block or otherwise prevent transactions that relate to:
(a) any Restricted Persons;
(b) weapons of any kind in contravention of applicable laws, including firearms, ammunition, explosives, or related accessories;
(c) controlled substances, including narcotics, prescription drugs, steroids, or related paraphernalia, unless duly licensed and authorised by the jurisdiction in which the User is based and the jurisdiction in which the transaction takes place;
(d) gambling activities, including sports betting, casino games, horse racing, or other activities that facilitate any of the foregoing, unless duly licensed and authorised by the applicable jurisdiction;
(e) money laundering or terrorist financing;
(f) any Ponzi scheme, pyramid scheme, or multi-level marketing program;
(g) goods or services that infringe or violate any copyright, trademark, or proprietary rights under the laws of any jurisdiction;
(h) any unlicensed money transmission activity;
(i) counterfeit goods, including fake or novelty identification documents;
(j) wash trading, front-running, insider trading, market manipulation, or other forms of market-based fraud or deceit;
(k) the purchase of goods of any type from darknet markets or any marketplace that facilitates trade in illegal goods; or
(l) any other activity, goods, or services that Wagyu communicates to Users from time to time as prohibited or unacceptable in connection with Wagyu (collectively, "Prohibited Transactions").
In the event that Wagyu determines that a User has engaged in any Prohibited Transaction, Wagyu will treat such conduct as a violation of this Policy and may block the relevant address from further interaction with Wagyu. No Assets will be frozen or seized solely on this basis; any such action requires a valid court order as set out in Section 5(a).
5. Blocked Addresses and Asset Seizure
Assets transacted through Wagyu are governed in accordance with this blocklisting policy. Wagyu's position, consistent with the standard publicly articulated by Circle CEO Jeremy Allaire, is that the freezing or seizure of Assets is not a matter of issuer discretion but of legal obligation, and will only occur pursuant to a valid court order or equivalent legal instrument from a duly authorised authority of competent jurisdiction.
Wagyu may take action with respect to addresses in the following circumstances:
(a) Legal Order. Wagyu may be required to freeze Assets in the event it receives a valid, binding, and enforceable legal order from a court of competent jurisdiction or a duly authorised government authority requiring it to do so. Wagyu will comply with binding court orders that have appropriate jurisdiction over Wagyu. A formal court order or equivalent legal instrument is required before Wagyu will act to freeze or seize User Assets. This requirement applies without exception.
(b) Sanctions and Restricted Persons. Where an address is determined to be associated with a Restricted Person or otherwise subject to applicable sanctions obligations, Wagyu reserves the right to block that address from accessing Wagyu, consistent with Wagyu's obligations under applicable sanctions law. Transactions will not be permitted to proceed and will be returned to the originating address. No Assets will be frozen or seized under this paragraph absent a court order as required by paragraph (a).
(c) Suspected Illegal Activity. Wagyu reserves the right to designate certain on-chain addresses as "Blocked Addresses" and to block such addresses from transacting through or otherwise interacting with Wagyu where Wagyu determines, in its sole discretion, that such addresses may be associated with illegal activity or activity that otherwise violates this Policy. Transactions from Blocked Addresses will not be permitted to proceed and will be returned to the originating address. For the avoidance of doubt, the blocking of an address from interaction with Wagyu under this paragraph does not involve the freezing or seizure of Assets. The freezing or seizure of Assets associated with a Blocked Address requires a valid court order or equivalent legal instrument as set out in paragraph (a).
The indefinite deprivation of a person's property on the basis of informal suspicion, unverified allegations, or internal risk determinations has no basis in law. It is a practice that has been misused extensively across the digital asset industry to justify what amounts to the appropriation of user funds by exchanges and protocols acting outside any legitimate legal authority. Wagyu categorically rejects this practice. The rule of law requires that asset seizure be authorised by a court of competent jurisdiction; suspicion alone, however well-founded, does not meet that threshold. Wagyu's enforcement capabilities with respect to Assets are therefore limited to what a court order expressly authorises.
Wagyu reserves the right to block the transfer of Assets to and from an address, and to block any address from interacting with Wagyu in any capacity, as permitted under this blocklisting policy.
6. Legal Compliance
Wagyu and all Assets transacted through it are subject to AML and CTF provisions, including applicable sanctions. By using Wagyu, you represent and warrant that your actions are not in violation of any applicable sanctions. Without limiting the foregoing, you may not use Wagyu if you are a Restricted Person or if you intend to transact with or on behalf of any Restricted Person.
7. Limitations and Disclaimers
(a) This Policy does not constitute legal advice. Users with questions regarding their legal rights or obligations in connection with their Assets or use of Wagyu should seek independent legal counsel.
(b) The legal and regulatory framework applicable to digital assets and bridging protocols varies across jurisdictions and is subject to change. This Policy sets out Wagyu's general operating standards and does not constitute a representation that Wagyu's practices satisfy the requirements of any particular jurisdiction.
(c) Users are aware of and accept the risk that Wagyu may be required to block address interactions in the circumstances specified in this Policy. The freezing or seizure of Assets will only occur upon receipt of a valid court order from a court of competent jurisdiction, as set out in Section 5(a). Users accept all consequences of transacting through Wagyu, including the risk of transaction failure resulting from technical difficulties, smart contract behaviour, or third-party infrastructure issues outside Wagyu's control.
(d) Wagyu may determine, in its sole discretion or due to legal or regulatory requirements, not to make its services available in certain jurisdictions or to certain Users.
Contact
For questions regarding this Policy or to serve legal orders, please contact:
Wagyu Compliance compliance@wagyu.xyz