Unauthorized Business Activity

Unauthorized Business Activity

Last Updated: December 2025 | Version 1.0

Table of Contents

1. Overview
2. Comprehensive Country Sanctions
3. Specially Designated Nationals (SDNs)
4. Cross-References
5. Contact

1. Overview

Instarails complies with OFAC regulations and has a robust OFAC compliance program. Instarails does not facilitate, directly or indirectly, interactions with sanctioned countries, entities, or individuals as described in this policy.

2. Comprehensive Country Sanctions

2.1 What Are Comprehensive Country Sanctions?

Sanctions can be comprehensive or specific to a country, individual, or entity (e.g., businesses). OFAC sanctions apply to US citizens, residents, and entities, regardless of their location.

Comprehensive country sanctions are the most broad-based prohibitions and prohibit a US Person (individual or entity) from dealing in various activities with a country, such as import/export, trade, financial transactions, etc.

2.2 Comprehensively Sanctioned Countries and Regions

Comprehensive country sanctions are currently imposed on:

• Burma/Myanmar
• Crimea Region of Ukraine
• Donetsk People’s Republic (DNR)
• Luhansk People’s Republic (LNR)
• Zaporizhzhia Region (added 2022)
• Kherson Region (added 2022)
• Cuba
• Iran
• North Korea
• Syria

2.3 Additional Restricted Countries

Instarails does not support interactions with Russia and Belarus, even though they are not comprehensively sanctioned countries.

3. Specially Designated Nationals (SDNs)

In addition to comprehensively sanctioned countries, and as part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for, or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers, designated under programs that are not country-specific.

Collectively, such individuals and companies are called “Specially Designated Nationals” or “SDNs.”

US persons, including individuals and entities such as Instarails, are prohibited from dealing with SDNs, including facilitating payments to or on behalf of SDNs.

The current SDN list is maintained by OFAC and is available at: OFAC SDN List

4. Cross-References

This policy should be read in conjunction with:

• General Terms of Service — Section 3.9 (Compliance with Laws)
• Acceptable Use Policy — Prohibited activities and industries
• Instarails Platform Rules — Section 4.2 (Validation and Screening), Section 9 (KYC/AML Partner Obligations)

5. Contact

If you have questions about this Unauthorized Business Activity policy, please contact us at support@instarails.io.

Instarails Inc.
131 Continental Drive, Suite 305
Newark, DE 19713