Address Screening

At each deposit, Bluefin screens wallet addresses using APIs provided by our partners to ascertain the risk associated with each address. When the risk score for a particular wallet address exceeds our thresholds, the wallet address in question is restricted from accessing the exchange.

Suppose a user has open positions or non-zero free collateral and is determined to have a risk score above our threshold. In that case, the user will immediately be restricted from depositing additional funds, adding margin, increasing open positions, or opening new positions. Any positions already existing at the time of classification may be closed using reduce-only orders, and any free collateral associated with the user’s account may be withdrawn. Once all open positions are closed and all free collateral is withdrawn, the wallet address in question will not be able to interact with the exchange.

Any level of exposure to the following entity categories will result in the risk associated with the wallet address exceeding our internal thresholds:

1. Sanctions

   Sanctions refer to entities listed on economic/trade embargo lists, such as by the US, EU, or UN, with which anyone subject to those jurisdictions is prohibited from dealing.

2. Terrorist Financing

   Terrorist financing pertains to the funding of designated terrorist groups and affiliates of terrorist groups, entities, and individuals.

3. Child Abuse Material

   Child abuse material includes forums and sites operating on the dark web, which facilitate the buying, selling, and spreading child sexual abuse material.

4. Special Measures

   Special Measures refers to entities or addresses identified by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) as “primary money laundering concern[s]” under its “Section 9714” or USA PATRIOT Act (section 311) authorities.

5. High-Risk Jurisdiction

   The high-risk jurisdiction category comprises cryptocurrency services based in specific jurisdictions, including Iran and Venezuela.

Please find below a list of additional entity categories and exposure thresholds:

Entity Category	Exposure Threshold
Darknet Market	≤ 10%
	≤ 10%
	≤ 10%
Mixing	≤ 10%
Ransomware	≤ 10%
Scam	≤ 10%
Stolen Funds	≤ 10%