Prohibited and Restricted Non-U.S. Jurisdictions List

As of July 17, 2025, zerohash will not conduct any business activity with any entity or individual located in the following countries and jurisdictions (new listings are noted in parentheticals as “New”):

• Afghanistan
• Albania (Western Balkans)
• Bahamas
• Belarus (c)
• Bosnia and Herzegovina (Western Balkans)
• Central African Republic
• Cuba
• Democratic Republic of the Congo
• Ethiopia
• Gaza Strip
• Germany (a)
• Guatemala (New)
• Guinea (New)
• Guinea-Bissau
• Haiti
• Iran
• Iraq
• Italy (a)
• Japan
• Kosovo (Western Balkans)
• Lebanon
• Libya
• Mali
• Montenegro (Western Balkans)
• Myanmar/Burma
• Nicaragua
• North Korea
• North Macedonia (Western Balkans)
• Pakistan (New)
• People’s Republic of China (PRC)
• PRC Special Autonomous Region (SAR) Hong Kong (b)
• Russia (c)
• Serbia (Western Balkans)
• Somalia
• South Sudan
• Spain (a)
• Sudan
• Syria
• Russian Occupied Regions of Ukraine (Crimea, Luhansk AKA LNR, Donetsk AKA DNR, Kherson, Zaporishia, etc.) (c)
• United Kingdom (d)
• Venezuela
• Yemen
• Zimbabwe

As of July 17, 2025, West Bank and Burundi are no longer included on this list and, therefore, reinstated as permitted.

Guatemala, Pakistan and Guinea have been added to this list as prohibited/restricted. No new customers will be permitted from these jurisdictions. Existing customers will be permitted to withdraw/sell existing assets. Establishment of any new relationships will be subject to Enhanced Due Diligence measures (EDD).

(a) As of November 1, 2023, no new customers from Germany, Spain, or Italy were permitted to be onboarded to Zero Hash LLC. Existing customers were permitted to withdraw/sell existing assets. Zero Hash LLC’s affiliate in Europe (zerohash europe) obtained their registration as a virtual asset service provider with the Dutch Central Bank (DNB) on 24 October 2024 and has received its license to operate under the MiCA Regulation in The Netherlands from the Authority for the Financial Markets (AFM) on 29 October 2025. zerohash clients that wish to offer crypto asset services into these countries should consult their zerohash relationship manager to include zerohash europe in their services.

(b) 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.

(c) Russia-Ukraine War policy established March 2022. Restrictions do not apply to territory controlled by the Government of Ukraine as of the time of this update.

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