Approach
Halfin restricts access to Services based on:
- Comprehensive international sanctions (OFAC, UN, EU, UK).
- FATF identification as high-risk or under increased monitoring.
- Internal risk assessment, including regulatory environment, AML enforcement maturity, and fraud incidence.
- Business decisions reflecting Halfin's commercial scope.
Restricted jurisdictions
Halfin does not establish business relationships with, or provide Services to, persons or entities located in, incorporated in, ordinarily resident in, or transacting from the following jurisdictions:
Comprehensive sanctions
- Cuba.
- Iran.
- North Korea (Democratic People's Republic of Korea).
- Syria.
- Crimea, Donetsk People's Republic, Luhansk People's Republic, Zaporizhzhia, and Kherson regions of Ukraine.
Subject to sanctions or significant restrictions
- Afghanistan.
- Belarus.
- Central African Republic.
- Democratic Republic of the Congo.
- Eritrea.
- Iraq.
- Lebanon.
- Libya.
- Mali.
- Myanmar (Burma).
- Russia.
- Somalia.
- South Sudan.
- Sudan.
- Venezuela.
- Yemen.
- Zimbabwe.
FATF higher-risk and enhanced-monitoring jurisdictions
This list reflects FATF guidance current at the date of this Policy. The applicable list may change.
- Algeria.
- Angola.
- Bulgaria.
- Burkina Faso.
- Cameroon.
- Côte d'Ivoire.
- Haiti.
- Kenya.
- Laos.
- Monaco.
- Mozambique.
- Namibia.
- Nepal.
- Nigeria.
- South Africa.
- Tanzania.
- Vietnam.
- Yemen.
Other restricted jurisdictions
- United Arab Emirates.
Application
Access to the Services from any of the above jurisdictions is prohibited regardless of whether the user employs a VPN, proxy, or other location-masking technology. Any attempt to bypass geographic restrictions is a material breach of the Terms of Use.
Halfin may screen access by IP address, KYB-declared business address, beneficial ownership residency, and other available signals. Detection of access from a restricted jurisdiction may result in immediate suspension or termination of the Merchant relationship.
Updates
This list is reviewed periodically and updated based on:
- Changes to sanctions regimes.
- FATF public statements and grey/blacklist updates.
- Halfin's internal risk assessment.
- Regulatory developments.
Change authority
Halfin may add or remove jurisdictions at any time without prior notice.