Miden Network - Legal & Compliance Disclosures
Part I - Sanctions Compliance Statement
Miden prohibits the use of the Miden network and all Miden-provided services, including Bread Wallet, the Faucet, the Bridge UI, and any Miden-hosted frontend, by any person or entity subject to sanctions administered by the U.S. Office of Foreign Assets Control (OFAC), the United Kingdom (UK Sanctions List), the European Union (EU Financial Sanctions / CSL), Israel (NBCTF designations), Japan (Economic Sanctions & Subject List), or France (Registre National des Gels), including persons located, organized, or resident in comprehensively sanctioned jurisdictions and entities owned or controlled by sanctioned persons (collectively, “Prohibited Users”).
The comprehensively sanctioned jurisdictions for the purposes of this Statement are, as of 20 October 2026:
| Jurisdiction | Basis |
|---|---|
| Cuba | OFAC comprehensive sanctions |
| Iran | OFAC comprehensive sanctions |
| North Korea | OFAC comprehensive sanctions |
| Crimea and Sevastopol | OFAC regional sanctions; EU and UK territorial restrictions |
| Non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine | OFAC regional sanctions; EU and UK territorial restrictions |
| Non-government-controlled areas of the Kherson and Zaporizhzhia oblasts of Ukraine | EU and UK territorial restrictions |
This list is reviewed when the underlying programs change. Persons designated under any of the programs named above are Prohibited Users wherever they are located.
Miden’s prevention model operates at three layers:
Infrastructure layer (network access). During the network’s initial centralized phase, all transactions are submitted through the sequencer operated by the Miden Foundation, the network operator. The sequencer’s gRPC endpoint is geoblocked for comprehensively sanctioned jurisdictions, so access from those jurisdictions is denied at the network level regardless of the client, wallet, or frontend used. The Faucet, which submits transactions on users’ behalf rather than through the user’s own client, carries its own equivalent geoblocking.
Application layer. Miden-hosted frontends and Bread Wallet apply additional application-level restrictions, including geoblocking and exclusion of comprehensively sanctioned territories from app-store distribution, on top of the network-level controls above. Bread Wallet applies a broader geographic access policy: all wallet access, including withdrawals, is blocked for connections from Cuba, Iran, North Korea, Russia, Belarus, Crimea, Sevastopol and the whole Donetsk, Luhansk, Kherson and Zaporizhzhia oblasts of Ukraine. The whole-oblast and Russia/Belarus restrictions are Bread Wallet application policy; they do not change the network-level jurisdiction list above. The App checks eligibility once at startup and keeps the decision for the page session. Without a successful startup eligibility decision, the wallet opens with Earn and Swap unavailable. New Earn deposits are additionally blocked for connections from the United Kingdom and the State of New York; that Earn-specific restriction permits withdrawals wherever wallet access is allowed.
Asset layer. Assets issued on Miden may carry on-chain compliance controls enforced at the protocol level. USDCx, for example, is subject to an on-chain blocklist on its issuing faucet: addresses designated on the sanctions lists above are frozen automatically within minutes of designation by an authorized freeze manager, and blocked addresses cannot send, receive, or bridge the asset regardless of the interface used. Enforcement occurs within the transaction proof itself, so it does not depend on wallet or frontend behavior. Freeze and unfreeze actions are recorded, evidenced by on-chain transactions, and retained for a minimum of five (5) years consistent with 31 CFR 501.601.
Legal process. Requests from law enforcement and asset-restriction orders are received and serviced by Miden at ops@miden.team, with the cooperation of relevant service providers. Miden complies with lawful reporting requests in coordination with law enforcement.
Part II - Prohibited-User Disclosure
The Miden network’s hosted services, Bread Wallet, the Faucet, the Bridge UI, and any Miden-hosted frontend, and compliance-controlled assets such as USDCx may not be used by Prohibited Users, as defined in the Sanctions Compliance Statement. By using these services, you represent that you are not a Prohibited User and are not acting on behalf of one.
Access from comprehensively sanctioned jurisdictions is restricted at the network level through geoblocking of the sequencer endpoint, and additionally at the application level. Attempted access from those jurisdictions may be denied without notice.
For compliance-controlled assets, enforcement is immediate and automatic: if your address is included on an applicable sanctions list, transactions involving your address will be denied, and transaction denial is your notice of blocked status. Frozen assets cannot be transferred, received, or bridged. Miden is not obligated to provide advance notice of blocking. Persons who believe they have been blocked in error may contact ops@miden.team; unblocking occurs only where consistent with applicable law, including any required authorization from the relevant authority.
During the network’s current operating period, transaction data, including data associated with private accounts and private notes, is stored by the network’s validators in encrypted form, and any two validators acting together can decrypt it. There are three validators, operated by the Miden Foundation, Gateway.fm and LambdaClass. No single validator operator can decrypt the data on its own; decryption requires two validators to cooperate and takes place only for network-integrity, compliance and legal purposes, including in response to a lawful request.