Draft pending legal review — this document is not yet final and must be reviewed by qualified counsel before it is relied upon.
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Export Compliance Statement

Last updated: 11 October 2026

1.Our Commitment

COOTOKENS is committed to complying with applicable export control, sanctions and related laws in each jurisdiction in which we operate and in each jurisdiction whose laws apply to the Services. We operate the Services as a compute capacity sourcing and delivery business and take compliance seriously as a condition of doing business.

2.Legal Framework We Observe

We conduct our business with reference to, among others: the export control and sanctions laws of the United States, including the Export Administration Regulations and the sanctions administered by the Office of Foreign Assets Control, and including restrictions relating to advanced computing items and to the screening of entities whose ultimate parent company is headquartered in a restricted jurisdiction; the export control and cross-border data laws of the People's Republic of China; and the export control and sanctions laws of other applicable jurisdictions.

3.How We Comply

  • (a) Eligibility screening and Know Your Customer. We verify the identity, registration and business of each customer before providing the Services.
  • (b) Ownership due diligence. We identify each customer's Ultimate Parent Company and beneficial owners, and the jurisdiction in which the Ultimate Parent Company has its headquarters.
  • (c) End-use and end-user screening. We review intended use cases, applications and end users, and screen against applicable restricted-party and sanctions lists.
  • (d) Refusal and suspension. We refuse orders, and suspend or terminate the Services, where screening, due diligence or regulatory requirements so require.
  • (e) Record-keeping and cooperation. We maintain compliance records and cooperate with competent authorities as required by law.
  • (f) Contractual controls. We incorporate compliance controls into our Terms of Service, Acceptable Use Policy and Order Forms.

4.What We Require of Customers

You must: (a) disclose your Ultimate Parent Company, beneficial owners and the jurisdiction of your Ultimate Parent Company's headquarters; (b) provide accurate end-use and end-user statements; (c) ensure that no Restricted Party obtains access to the Services; (d) not transfer, resell or provide access to any prohibited person; (e) comply with all applicable export control and sanctions laws; (f) cooperate with our audits and record requests; and (g) notify us promptly of relevant changes.

5.No Facilitation of Evasion

COOTOKENS does not design, facilitate, participate in or advise on any structure, arrangement or transaction intended to circumvent export controls, sanctions or other legal restrictions.

We will not assist any person in concealing ultimate ownership, ultimate parentage, location or end use for the purpose of obtaining access that would otherwise be prohibited. Where we become aware of any such conduct, we will refuse or terminate the Services and may report the matter to the competent authorities.

6.Regulatory Change

We monitor regulatory developments. Where a change in law, regulation or authority action affects the lawfulness or feasibility of providing the Services, we may suspend or terminate the affected Services. You acknowledge that the legal environment may change and that continued provision of the Services may become unlawful.

7.Records and Cooperation

We retain compliance records for the periods required by applicable law, and we cooperate with competent authorities within the limits of applicable law.

8.Contact

For questions about export compliance, contact compliance@cootokens.com.