Updated List of Prohibited, Restricted, and Permitted Higher Risk Jurisdictions (2026 Annual List Update)

Effective date

May 19, 2026

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 zerohash:
- Existing Participants: The Platform must ensure that any existing participants in Singapore sell or withdraw all existing assets held with zerohash by June 19, 2026.
- New Participants: Platforms must immediately ensure no new participants located in these jurisdictions are submitted to zerohash. zerohash will decline any such submitted participants.

Summary

To ensure compliance with its targeted financial sanctions obligations and mitigate identified Anti Money Laundering/Countering the Financing of Terrorism/Countering the Financing of the Proliferation of Weapons of Mass Destruction (AML/CFT/CFP) risks, zerohash prohibits or restricts business activity involving certain jurisdictions and countries. zerohash also identifies other permitted geographies that are considered higher risk. zerohash reviews both of these lists at least annually and based upon relevant changes in legal and regulatory requirements and applicable AML/CFT/CFP risks.

zerohash is issuing this notice to inform Platforms and other stakeholders of updates to the jurisdiction and country lists, which are effective within 30 days of this notice June (INSERT THE DATE), 2026 unless otherwise noted.

Updates to zerohash List of Prohibited or Restricted Jurisdictions

Additions

Singapore

Removals

Guatemala, Guinea, Guinea-Bissau, Pakistan, and Zimbabwe
All will be added to the list of Permitted Higher Risk Geographies for a minimum of one year, extendable upon identification of risk-based reasons for continuation on that list.

Explanation of Treatment of Prohibited and Restricted Jurisdictions

Except as otherwise explicitly noted, zerohash will not do business with any entity or person located or formed in a prohibited or restricted jurisdiction. This applies to Platform partners and institutional or individual customers of zerohash llc and zerohash liquidity services llc and its various affiliates (collectively, zerohash) and the natural person or non-natural person (NNP) customers or transactors of any Platform partner.

Handling of Participants in Newly Listed Prohibited or Restricted Countries or Jurisdictions:

When a country or jurisdiction becomes listed, all existing zerohash direct or indirect business relationships will be revoked (immediately, if required by law or regulation) and accounts closed. Platform participants will be permitted to withdraw/sell their cryptocurrency holdings (unless prohibited by law or regulation).

Process for Restarting Relationships Involving Delisted Countries/Jurisdictions:

When a country or jurisdiction is removed from the list (delisted), zerohash will begin to permit the establishment of new business relationships, including with new Platform participants. Establishment of any new relationships will be subject to enhanced due diligence measures, unless the restriction was based solely on zerohash first having to obtain a license or registration in that jurisdiction.

Updates to zerohash’s List of Permitted Higher Risk Jurisdictions

zerohash is updating its list of Permitted Higher Risk Geographies based upon the FATF’s “Grey List” updates of October 2025 and February 2026, and other public and proprietary assessments of AML/CFT/CFP, fraud, corruption, and other relevant risks. Additional limitations and restrictions may be placed on any or all of the jurisdictions listed below depending upon the specific zerohash product or service being provided or for other applicable reasons: