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Updated List of Prohibited, Restricted, and Permitted Higher Risk Non-U.S. Jurisdictions

May 1st, 2024

Release Information

  • Release Date: May 1, 2024

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:
    • Existing Participants: The Platform must ensure that any existing participants in the West Bank sell or withdraw all existing assets held with Zero Hash by May 31, 2024.
    • New Participants: Platforms must immediately ensure no new participants located in these jurisdictions are submitted to Zero Hash. Zero Hash 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, Zero Hash prohibits or restricts business activity involving certain jurisdictions and countries. Zero Hash also identifies other permitted geographies that are considered higher risk. Zero Hash reviews both of these lists at least annually and based upon relevant changes in legal and regulatory requirements and applicable AML/CFT/CFP risks.

Zero Hash 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 (May 31, 2024) unless otherwise noted.

Updates to Zero Hash List of Prohibited or Restricted Jurisdictions

Additions

  • West Bank
  • Germany¶
  • Spain¶
  • Italy¶

Removals

  • The Netherlands

¶ Since November 1, 2023, no new customers have been or will be permitted from Germany, Spain, or Italy until Zero Hash has obtained the necessary licensing. Existing customers have and will continue to be permitted to withdraw/sell existing assets. The West Bank has been added to the list as a result of various new targeted financial sanctions. This restriction no longer applies to The Netherlands as Zero Hash received its license to operate there on March 18, 2024.

Explanation of Treatment of Prohibited and Restricted Jurisdictions

Except as otherwise explicitly noted, Zero Hash 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 Zero Hash LLC and Zero Hash Liquidity Services LLC and its various affiliates (collectively, Zero Hash) and the natural person or non-natural person (NNP) customers 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 Zero Hash 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), Zero Hash 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 Zero Hash first having to obtain a license or registration in that jurisdiction.

Updates to Zero Hash’s List of Permitted Higher Risk Non-U.S. Geographies

Zero Hash is updating its list of Permitted Higher Risk Geographies based upon the FATF’s “Grey List” updates of February 23, 2024, and other public and proprietary assessments of AML/CFT/CFP, fraud, corruption, and other relevant risks:

Additions

  • Kenya
  • Namibia

Removals

  • Barbados
  • Gibraltar
  • Uganda
  • Jordan
  • Panama

Related Documentation

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