In addition to conducting KYC during onboarding and requiring Gemini Derivatives customers to certify their status as non-U.S. Persons and their physical presence in a country in which Gemini Derivatives is available, Gemini Derivatives implements GeoIP blocking to prevent customers from attempting to conduct activity on the Gemini Derivatives platform from an IP address known to be located in the United States, and also maintains controls to detect the use of Virtual Private Networks (VPNs) to attempt to evade Gemini Derivatives’s GeoIP blocking.