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Updated List of Jurisdictions

June 10th, 2023

THIS LIST HAS BEEN REPLACED AS OF MAY 1, 2024

See update at: 2024-05-01 Updated List of Prohibited, Restricted, and Permitted Higher Risk Non-U.S. Jurisdictions

Release Date

  • Prod: October 6, 2023 (Updated October 31, 2023)
  • Platform Implementation Requirement Dates:
    • October 8, 2023 (UK only)
    • December 1, 2023 (all other countries and jurisdictions except as noted below)

Release Type

  • Actionable – Updates required for platforms
  • Breaking – If appropriate IP and other preventive measures are not made by the relevant dates, Platforms will have newly submitted participants located in certain countries declined by Zero Hash:

Summary

Zero Hash has implemented prohibitions or restrictions on business activity with or in certain jurisdictions and countries, in compliance with legal and regulatory requirements. Updates have been made to the list of prohibited, restricted, and permitted higher-risk geographies.

Updated list

Following the recent completion of its latest review, Zero Hash is updating its list of prohibited and restricted list to the following countries and jurisdictions or geographies (new listings are noted in parentheticals):

Prohibited (Tier 1)

  • Belarus
  • Central African Republic
  • Democratic Republic of the Congo
  • Cuba
  • Gaza Strip (added October 31, 2023)
  • Iran
  • Iraq
  • North Korea
  • Lebanon (new)
  • Libya (new)
  • Mali (new)
  • Russia*
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Russian Occupied Regions of Ukraine (Crimea, Luhansk AKA LNR, Donetsk AKA DNR)* (does not apply to territory controlled by the Government of Ukraine)
  • Yemen
  • Zimbabwe

*Russia-Ukraine War policy established March 2022.

Restricted (Tier 2)

  • Afghanistan
  • Albania (Western Balkans) (new)
  • Bosnia and Herzegovina (Western Balkans)
  • Burundi
  • Ethiopia
  • Guineau Bisseau (new)
  • Haiti (new)
  • Kosovo (Western Balkans)
  • Montenegro (Western Balkans) (new)
  • Nicaragua (new)
  • North Macedonia (Western Balkans) (new)
  • Serbia (Western Balkans) (new)
  • Venezuela (new)
  • Restricted (Tier 3)
  • Bahamas
  • People’s Republic of China (PRC)†
  • Japan
  • PRC Special Autonomous Region (SAR) Hong Kong‡
  • The Netherlands¶ (added October 31, 2023)
  • The United Kingdom§ (new)

† Additional limitations related to the People's Republic of China: No Platform or business with more than 50% Chinese investors will be approved as a customer of Zero Hash.

‡ As of June 1, 2023, all participant types from Hong Kong are blocked from onboarding and buying/acquiring assets. Existing participants are blocked from buying/acquiring assets but will be allowed to 1) sell/withdraw and 2) update their address if they are no longer located in Hong Kong.

§ As of October 8, 2023, no new customers will be permitted from the United Kingdom until Zero Hash has obtained the necessary licensing. Existing customers will be permitted to withdraw/sell existing assets.

¶ As of November 1, 2023, no new customers will be permitted from The Netherlands until Zero Hash has obtained the necessary licensing. Existing customers will be permitted to withdraw/sell existing assets.

Permitted Higher Risk Geographies

Following the recent completion of its latest review, Zero Hash also has established a new list of Permitted Higher Risk Geographies for which Enhanced Due Diligence measures will be applied to all existing and new Platform, business, and individual customers of Zero Hash and all Platform participants (whether natural or non-natural persons).

The following countries and jurisdictions or geographies are included in this list, which is based upon the FATF’s “Grey List” and other public and proprietary assessments of AML/CFT/CFP, fraud, corruption, and other relevant risks**:

  • Barbados
  • Bulgaria (added October 31, 2023)
  • Burkina Faso
  • Cameroon
  • Croatia
  • Gibraltar
  • Jamaica
  • Jordan
  • Mozambique
  • Nigeria
  • Panama
  • Philippines
  • Senegal
  • South Africa
  • Tanzania
  • Turkey
  • Uganda
  • United Arab Emirates
  • Vietnam

** As of November 1, 2023, the Cayman Islands is no longer included on this list.

Actions required

Platforms

Platforms must ensure they adhere to Zero Hash’s requirements for existing participant accounts in prohibited or restricted countries and jurisdictions and ensure no new participants are onboarded with Zero Hash.

Platforms must ensure they are able to properly and consistently identify the location (both at time of onboarding and for transactions) of participants consistent with Zero Hash’s requirements.

For additional general information regarding the U.S. geographies that Zero Hash supports, please also refer to Permitted and Restricted Jurisdictions.