Restricted jurisdictions

S1.1What is a Restricted Jurisdiction. A "Restricted Jurisdiction" is any country, territory or region:

1. (a)that is subject to comprehensive or territorial Sanctions, or whose government is the subject or target of Sanctions;
2. (b)that is identified by the Financial Action Task Force (FATF) as a high-risk jurisdiction subject to a call for action;
3. (c)in which the provision of the Services, or of any particular Service, by us or by a Payment Partner is prohibited or requires a licence, registration or authorisation that we or the Payment Partner do not hold; or
4. (d)that we have otherwise designated as restricted in accordance with our risk assessment.

S1.2Published list. We publish the current list of Restricted Jurisdictions on the Website and in the Platform. We update the list as Sanctions, FATF statements, Applicable Law and our risk assessment change, and changes take effect immediately on publication. A jurisdiction may be restricted for some Services and not for others.

S1.3Increased-risk jurisdictions. Clients connected with jurisdictions identified by the FATF as subject to increased monitoring, or that we consider to present a higher risk, may be accepted only after enhanced due diligence, and may be subject to additional restrictions and lower limits.

S1.4Geographic controls. We use information about your incorporation, operating locations, beneficial owners, IP addresses and devices to apply these restrictions. Access to the Platform from a Restricted Jurisdiction, including through a VPN or proxy, is prohibited and may result in the suspension of your Account.

S1.5If a jurisdiction becomes restricted. If a jurisdiction connected with you becomes a Restricted Jurisdiction, we may restrict or terminate your Account. Where Sanctions do not prohibit it, we will allow you to withdraw your Client Assets and Client Funds to an account or address in your name that is permitted under Applicable Law. Where Sanctions apply, we will freeze the relevant Client Assets and Client Funds and act in accordance with Applicable Law and the instructions of the competent Governmental Authorities.