Last updated: December 4, 2025

This document sets out jurisdictions classified as restricted (“Restricted Jurisdictions”) and those subject to enhanced treatment (“High-Risk Jurisdictions”). The classification combines ur internal compliance and operational criteria with widely recognized external references, including FATF guidance and lists and international sanctions (primarily the United Nations and U.S. OFAC, as well as the European Union and the United Kingdom).

Inclusion in either category results, as applicable, in a prohibition on relationships/activities or the application of Enhanced Due Diligence (“EDD”) measures, with documentation, approval, and ongoing monitoring.

1. Restricted Jurisdictions
   The following jurisdictions are considered restricted. No transactions, partnerships, or business relationships will be established with individuals or entities based in, incorporated in, operating from, or otherwise connected to these locations.
   
   Transactions will also be declined if they directly or indirectly involve goods, services, funds, counterparties, or commercial activities linked to these jurisdictions, including where documentation indicates that products, services, or underlying activity are located in or connected to a restricted country, even if the transacting parties are not.

   • Cuba

   • North Korea

   • Iran

   • Syria

   • Burma (Myanmar)

   • The Crimea, Donetsk and Luhansk regions, and any other areas not controlled by the Government of Ukraine

   • Sudan

   • Lebanon

   • Russia

   • Belarus

   • Venezuela

   • Macau

   • Algeria

   • Egypt

   • Bangladesh

   • Afghanistan

   • Bolivia

   • North Macedonia

   • Ecuador

   • Nepal

   • Morocco
     
     

2. High-Risk Jurisdictions
   For the jurisdictions below, activities are automatically subject to EDD procedures, including in-depth risk assessment, enhanced identity verification, ultimate beneficial owner analysis, and ongoing monitoring:

   • Angola

   • Bulgaria

   • Burkina Faso

   • Cameroon

   • Colombia

   • Côte d’Ivoire (Ivory Coast)

   • Croatia

   • People’s Republic of China

   • Democratic Republic of the Congo

   • Haiti

   • Kenya

   • Lao People’s Democratic Republic (Laos)

   • Mali

   • Monaco

   • Mozambique

   • Namibia

   • Nigeria

   • Tanzania

   • Vietnam

   • Yemen

   • Central African Republic

   • Iraq

   • Libya

   • Somalia

   • Panama

   • Zimbabwe

3. General Provisions
   This list may be updated at any time to reflect changes in international sanctions, applicable national laws, or internal compliance policies. Exceptional cases must be reviewed and approved in advance by the Compliance Department, with a formal record of the decision and the safeguards applied.