List of Restricted or Sanctioned Countries

Sanctioned Country Policy

Cross-border payments compliance requires us to maintain strict restrictions on transactions involving certain jurisdictions. These restrictions draw on OFAC (the US Treasury's Office of Foreign Assets Control), United Nations sanctions lists, prevailing international anti-money-laundering and counter-terrorist-financing (AML/CFT) standards, and our own risk assessment.

If your operation touches any of the countries below—as either a source or destination—we need to discuss it directly with you before we can proceed.

Prohibited Jurisdictions — Call for Action (No Exceptions)

These jurisdictions are subject to the strongest international call for action, including countermeasures, and are under comprehensive US and UN sanctions. We do not process any transactions to or from them.

Democratic People's Republic of Korea (DPRK): Comprehensive sanctions; subject to countermeasures.
Iran: Comprehensive sanctions; subject to countermeasures.

Highest-Risk — Call for Action (Enhanced Due Diligence)

This jurisdiction is subject to an international call for action that requires enhanced due diligence proportionate to the risk. We do not maintain ongoing corridors here and will consider individual transactions only under the strictest scrutiny.

Myanmar (Burma): Call for action; enhanced due diligence required.

Jurisdictions Under Increased Monitoring (Case-by-Case, Enhanced Due Diligence)

These jurisdictions have been identified internationally as having strategic AML/CFT deficiencies and are working under an agreed action plan to address them. This is not a sanctions list. We may support transactions to or from these countries, but only after enhanced due diligence on the specific counterparties and the purpose of each transaction:

Angola
Bolivia
Bosnia and Herzegovina
Bulgaria
Cameroon
Côte d'Ivoire
Democratic Republic of the Congo
Haiti
Iraq
Kenya
Kuwait
Laos (Lao PDR)
Lebanon
Monaco
Nepal
Papua New Guinea
South Sudan
Syria
Venezuela
Vietnam
Virgin Islands (UK)
Yemen

Separately Sanctioned Jurisdictions

Independent of the categories above, any country or region subject to comprehensive OFAC or UN sanctions is also off-limits, regardless of its monitoring status. If you are unsure whether a specific jurisdiction or region is affected, ask us before you build any flow around it.

What This Means for Your Business

If your operation involves any of these countries—even tangentially—disclose it upfront during your initial consultation. We'll assess the specific risk, the nature of the transactions, and the parties involved. In many cases, legitimate business can proceed, but we need full transparency and thorough due diligence first.

Because these lists are reviewed and revised several times a year, a country's status can change. We reassess every engagement against the current lists at the time of onboarding.

Failing to disclose sanctions exposure can result in immediate termination of our relationship and potential regulatory reporting obligations on our part.