Restricted jurisdictions

We check before, not after

Jurisdiction is established during verification, before any funds move. We would rather decline a deal at the start than freeze funds mid-transaction, which is what happens when a service checks late.

This page reflects the position at August 2026. Sanctions and monitoring lists change, sometimes at short notice. We review it monthly and on any listing change.

Comprehensive sanctions: we cannot act at all

These are subject to broad prohibitions under one or more of the US (OFAC), UN, EU and UK regimes:

• Cuba
• Iran
• North Korea
• Syria
• Crimea, Donetsk and Luhansk regions of Ukraine

Syria is in flux. Significant sanctions easing occurred during 2025 and the current position needs confirmation against OFAC's own guidance before any Syrian-nexus deal is considered. We treat it as fully restricted until counsel confirms otherwise.

Sanctioned persons and entities

Regardless of location, we cannot act for any individual or entity subject to applicable sanctions, nor for anyone acting on their behalf. Screening covers both parties and every wallet involved.

FATF high-risk jurisdictions: call for action

Subject to countermeasures, treated as restricted:

• North Korea and Iran: countermeasures apply
• Myanmar: enhanced due diligence applies, with countermeasures under consideration at the October 2026 plenary

FATF increased monitoring: enhanced checks, not refusal

Twenty-two jurisdictions are currently on the list for increased monitoring, following the June 2026 plenary at which Bosnia and Herzegovina and Iraq were added and Algeria and Namibia removed.

A deal touching one of these attracts enhanced due diligence (deeper source-of-funds work, closer scrutiny of the structure) rather than an automatic refusal.

Kuwait itself has been on this list since 13 February 2026. That is a statement about national AML frameworks, not about Kuwaiti customers, and it does not stop us acting for them. It does mean deals with a Kuwait nexus attract more scrutiny from correspondent banks and counterparties than they did previously, and we would rather you heard that from us.

Crypto-specific restrictions

The EU's twentieth sanctions package prohibits transactions with Russian and Belarusian crypto-asset service providers. The twenty-first, adopted 23 July 2026, names fourteen platforms across six jurisdictions, including the UAE, which is directly relevant to where a Gulf escrow business licenses itself.

Where local law prohibits the service

We do not offer this service to residents of the United States, and we do not accept US persons as defined under US law. More generally we decline where providing the service to you would require an authorisation we do not hold in your own jurisdiction.

Our licence perimeter is Bahrain. A Category 2 Crypto-Asset Services Company Licence authorises us in the Kingdom of Bahrain; it does not passport anywhere. Every client outside Bahrain is served cross-border, which means the question is not "are we licensed?" but "does your jurisdiction require a local authorisation for what we are doing for you?" Where it does and we do not hold one, we decline. That is the rule this list applies, rather than a fixed roster we hope stays current.

This list is reviewed monthly, on any listing change, and whenever our permitted activities change. If we ever add an activity to our licence, the perimeter question is re-run for every jurisdiction we serve before that activity is offered to anyone.

Kuwait specifically

Kuwait is not a restricted jurisdiction on this list, and we want to be clear about why.

Kuwait's position is materially different from a sanctions restriction and should not be confused with one. Kuwait prohibits the activity domestically and licenses no one to perform it. That is a question about our permission to operate a business there, which we do not claim, not about your eligibility to be our client.

CMA Circular No. (10) of 2023 is addressed to financial institutions and designated non-financial businesses and professions in Kuwait. We are neither, and neither are you as an individual. The circular expressly contemplates virtual-asset transactions "executed outside the State of Kuwait with the knowledge of clients", and what it requires in relation to those is that clients be constantly informed of the risks: a continuing disclosure duty, not a prohibition on the client.

So: we serve Kuwaiti residents cross-border under our Bahraini licence, we do not hold or claim any Kuwaiti authorisation, and we discharge the disclosure standard the Kuwaiti regulator considers appropriate for cross-border dealing even though it binds Kuwaiti institutions rather than us. Our Risk Disclosure and Regulatory status pages are how we do that, and they are linked from the footer of every page for that reason rather than for decoration.

What this does not do is give you Kuwaiti recourse. Your contract is Bahraini and your remedies are Bahraini. That trade-off is set out in full on the Regulatory status page and you should read it before your first deal, not after.

If your circumstances change

Tell us. If you relocate during a live deal the position may change, and we may need to complete or unwind it differently.

Not a judgement

A restriction here reflects a legal or regulatory constraint on us. It is not a statement about you.