Restricted Jurisdictions · Operator Obligations · Disconnection Protocol
sprutgaming.com · Version 1.0 · Effective 2025 · Public Document
FUNDAMENTAL POSITION — SOFTWARE PROVIDER ONLYSprut Gaming operates exclusively as a technology and software provider. Sprut Gaming licenses platform software, APIs, back-end infrastructure and related technology services to independent operators on a B2B basis. Sprut Gaming does NOT operate gambling services, does NOT accept wagers, does NOT hold end-user funds, and does NOT hold any gaming licence in respect of end-user activity. Sprut Gaming bears NO civil, criminal, regulatory or administrative liability whatsoever for any violation of gambling laws, payment regulations, AML/CFT obligations or any other legal or regulatory requirement arising from the activities of any Operator or its end-users in any jurisdiction, including any Restricted Jurisdiction listed in this Policy. Full and exclusive legal responsibility for regulatory compliance rests solely with the Operator.
This Geo-Restriction & Compliance Policy ("Policy") is a public document published by Sprut Gaming. It sets out: (i) the Restricted Jurisdictions in which Operators are prohibited from using Sprut Gaming's software; (ii) the technical and contractual obligations applicable to all Operators; and (iii) the disconnection procedure applicable upon any breach.
This Policy forms an integral part of every Software Usage Agreement between Sprut Gaming and any Operator. By entering into a Software Usage Agreement, the Operator confirms it has read, understood and agreed to this Policy. In the event of any conflict, this Policy prevails. Continued use of Sprut Gaming's software following publication of an updated version constitutes unconditional acceptance of the updated terms.
LEGAL DISCLAIMER — READ CAREFULLYSprut Gaming expressly disclaims all liability — civil, criminal, regulatory, administrative or otherwise — for any act or omission of any Operator or its end-users, including but not limited to: (a) the provision, marketing or facilitation of gambling or gaming services in any jurisdiction; (b) any violation of applicable gambling laws, licensing requirements, AML/CFT rules, payment regulations, data protection legislation or any other regulatory obligation; (c) any breach of the Restricted Jurisdictions provisions of this Policy; (d) any claim brought by a regulatory authority, governmental body or third party arising from the Operator's activities. This disclaimer applies regardless of whether Sprut Gaming was or ought to have been aware of the Operator's activities.
Operators are strictly and absolutely prohibited from using Sprut Gaming's software, platform infrastructure, APIs or any related services to provide, market or facilitate any services — directly or indirectly — to end-users located in or accessing from any Restricted Jurisdiction. This list is OPEN-ENDED and NON-EXHAUSTIVE.
| Jurisdiction | Legal Basis | Category |
|---|---|---|
| Republic of Armenia | Statutory prohibition on gambling | Statutory Ban |
| Republic of Azerbaijan | Statutory prohibition on gambling | Statutory Ban |
| Republic of Belarus | Statutory prohibition on gambling | Statutory Ban |
| People's Republic of China | Statutory prohibition on gambling | Statutory Ban |
| Federal Republic of Germany | Mandatory licensing / restricted market | Licence Required |
| State of Israel | Statutory prohibition on gambling | Statutory Ban |
| Islamic Republic of Iran | UN / EU / OFAC sanctions + statutory prohibition | Sanctions + Ban |
| DPRK (North Korea) | UN / OFAC / EU / UK sanctions + prohibition | Sanctions + Ban |
| Kingdom of the Netherlands | Mandatory licensing / restricted market | Licence Required |
| Republic of Poland | Mandatory licensing / restricted market | Licence Required |
| Portuguese Republic | Mandatory licensing / restricted market | Licence Required |
| Russian Federation | Statutory prohibition + international sanctions | Sanctions + Ban |
| Kingdom of Spain | Mandatory licensing / restricted market | Licence Required |
| Republic of Costa Rica | Statutory prohibition on gambling | Statutory Ban |
| Republic of the Union of Myanmar | FATF High-Risk + statutory prohibition | FATF + Ban |
| Republic of Uzbekistan | Statutory prohibition on gambling | Statutory Ban |
| United Kingdom of Great Britain and NI | Mandatory UKGC licensing | Licence Required |
| United States of America | Federal & state statutory prohibition | Statutory Ban |
| Republic of Turkey | Statutory prohibition on gambling | Statutory Ban |
| FATF High-Risk Jurisdictions (dynamic) | FATF Call for Action — applied automatically | Dynamic / FATF |
| UN / EU / OFAC / UK Sanctioned Territories (dyn.) | All applicable sanctions regimes | Dynamic / Sanctions |
| Any jurisdiction lacking required licence (dyn.) | Regulatory requirement — licence mandatory | Dynamic / Regulatory |
OPEN-ENDED LIST — RIGHT TO UPDATE WITHOUT PRIOR NOTICESprut Gaming reserves the absolute and unconditional right to add, remove or reclassify any jurisdiction at any time, including: (i) any jurisdiction newly included in the FATF High-Risk / Call for Action list; (ii) any new sanctions territory designated by the UN, EU, OFAC, UK HM Treasury or any other competent authority; (iii) any jurisdiction which Sprut Gaming, at its sole discretion, determines presents legal, regulatory, reputational or compliance risk. Named jurisdiction updates take effect upon publication at sprutgaming.com. Dynamic categories (FATF, sanctions) take effect automatically upon official designation — no amendment to this Policy document is required.
ZERO TOLERANCE — VPN / PROXY FACILITATIONThe Operator must not knowingly permit, facilitate, encourage or tolerate the use of VPN services, proxy servers, Tor exit nodes or any other anonymisation technology that conceals the end-user's true jurisdiction of access. Detection of deliberate VPN or proxy facilitation constitutes an automatic and irremediable material breach of the Software Usage Agreement and triggers immediate permanent termination of all access to Sprut Gaming's platform — with no right of cure or reinstatement.
Upon becoming aware of any actual or reasonably suspected breach of this Policy, Sprut Gaming shall take the following measures immediately, unilaterally, without prior notice, and without incurring any liability to the Operator:
| Jurisdiction | Legal Basis | Category |
|---|---|---|
| Access from Restricted Jurisdiction detected | Technical suspension of Operator access | Compliance audit within 7 days |
| Geo-blocking absent or insufficient | Full disconnection from the Platform | Termination of Software Agreement |
| Payment processing from Restricted Jurisdiction | Suspension + transaction freeze | Termination + refund procedure |
| VPN / proxy facilitation confirmed | IMMEDIATE PERMANENT TERMINATION | Referral to competent authorities |
| Repeated or wilful breach | IMMEDIATE PERMANENT TERMINATION | Indemnity claim and legal action |
| Activity in a sanctioned jurisdiction | IMMEDIATE PERMANENT TERMINATION | Regulatory disclosure if required |
RIGHT TO IMMEDIATE DISCONNECTION — NO LIABILITY TO OPERATORSprut Gaming may disconnect, suspend or terminate any Operator's access to the platform IMMEDIATELY, unilaterally and without liability, upon becoming aware — or having reasonable grounds to suspect — that the Operator is engaged in or facilitating activity in any Restricted Jurisdiction or is otherwise in breach of this Policy. No prior notice, cure period, mediation or judicial process is required as a precondition for the exercise of this right. Sprut Gaming's right to seek damages and indemnification survives any disconnection or termination.
The Operator shall, at its own cost and expense, fully indemnify, defend and hold harmless Sprut Gaming, its shareholders, directors, officers, employees, agents and successors from and against any and all losses, liabilities, damages, costs and expenses, including:
— arising directly or indirectly from: (i) the Operator's activities in any Restricted Jurisdiction; (ii) any breach of this Policy; or (iii) any violation of applicable law by the Operator or its end-users.
SURVIVALIndemnification obligations survive the termination or expiry of the Software Usage Agreement for any reason and are not limited in amount.