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

July 17th, 2025

Release date

July 17, 2025

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 Guatemala, Pakistan, and Guinea sell or withdraw all existing assets held with zerohash by August 16, 2025.
    • 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 (August 16, 2025) unless otherwise noted.

Updates to zerohash List of Prohibited or Restricted Non-U.S. Jurisdictions

Additions

  • Guatemala
  • Guinea
  • Pakistan

Removals

  • West Bank
  • Burundi

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 Zero Hash LLC and Zero Hash 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 (EDD), unless the restriction was based solely on zerohash first having to obtain a license or registration in that jurisdiction.

Updates to Zero Hash’s Permitted Higher Risk Non-U.S. Jurisdictions

zerohash is updating its list of Permitted Higher Risk Geographies based upon the FATF’s “Grey List” updates of June 13, 2025, and other public and proprietary assessments of AML/CFT/CFP, fraud, corruption, and other relevant risks:

Additions

  • Algeria
  • Angola
  • Bolivia
  • Cote d’Ivoire
  • Lao People’s Democratic Republic
  • Monaco
  • Nepal
  • Virgin Islands (UK)

Removals

  • Croatia
  • Jamaica
  • Philippines
  • Senegal
  • Tanzania
  • Turkey (Türkiye)

Related Documentation

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