Restricted Jurisdictions

Version 1.0 · Effective [[Effective date]] · Last updated [[Effective date]]

In short: Paysell does not serve merchants connected to comprehensively sanctioned countries and territories, or merchants operating where crypto-asset payment services are prohibited. The table below is indicative and maintained by Paysell — it is not a statement of law, it changes, and you must satisfy yourself about the rules that apply to you and to your buyers.

1. Purpose#

1.1 This document explains how [[Company legal name]] ("Paysell") approaches geographic restrictions, and gives an indicative list of the countries and territories currently treated as restricted.

1.2 It forms part of the Terms of Service and supports the AML/CTF and Sanctions Policy.

1.3 This is not legal advice and is not a statement of the law of any country. Sanctions regimes and crypto-asset rules change frequently, differ between jurisdictions and are sometimes contested. Paysell maintains this list for its own risk management. You must obtain your own advice.

2. How the list is built#

Paysell restricts a jurisdiction for one or more of the following reasons.

2.1 Comprehensive sanctions#

Countries and territories that are the subject of comprehensive or near-comprehensive sanctions under the regimes that bind Paysell, or under the major international regimes Paysell chooses to observe as a matter of policy — typically those administered by the United Nations Security Council, the European Union, the United States Office of Foreign Assets Control, and the United Kingdom.

2.2 Prohibition of crypto-asset activity#

Jurisdictions in which the acceptance of crypto-asset payments, the operation of crypto-asset services, or the holding of crypto-assets by residents is prohibited or effectively prohibited, whether by statute, by central bank instruction or by enforcement practice.

2.3 Licensing that Paysell does not hold#

Jurisdictions where providing a custodial crypto-asset payment service requires a license or registration that Paysell does not hold. See the Regulatory Status Statement. Restriction on this ground is a decision about Paysell's own permissions, not a judgment about the merchant.

2.4 Unacceptable risk#

Jurisdictions where, in Paysell's assessment, the combination of sanctions exposure, fraud rates, enforcement risk or the inability to verify merchants makes the relationship unacceptable.

3. Indicative restricted list#

Owner note: this table must be confirmed with counsel against the regimes that actually bind the company before publication, and reviewed at least quarterly. Add or remove entries as advised, and update the review date each time.

Paysell may also restrict individual regions of a country, individual business categories within a country, or individual merchants, without restricting the country as a whole.

Last reviewed by Paysell: [[Date of last list review]].

4. Additional restrictions independent of this list#

4.1 Paysell will not provide the Services to a person or entity that is itself designated under a sanctions regime, wherever located, or that is owned or controlled by such a person, regardless of whether their country appears in the table.

4.2 Paysell will not process a transaction that Paysell believes is intended to benefit a restricted jurisdiction or a designated person indirectly, including through an intermediary, a shell company or a nominee.

4.3 Restrictions apply to the merchant, to its owners and controllers, to its place of establishment and operation, and to the markets it sells into.

5. What this means for merchants#

5.1 You must not register or operate a shop if you, your business, your owners or your controllers are established in, ordinarily resident in, or operating from a restricted jurisdiction.

5.2 You must not use the Services to sell to buyers in a restricted jurisdiction, and must block them by whatever means your platform allows.

5.3 You must not use a VPN, proxy, intermediary company or nominee to conceal a connection to a restricted jurisdiction. Doing so is a material breach of the Terms of Service and will lead to termination, a hold on your balance and, where required, a report to the authorities.

5.4 You must tell Paysell without delay if your circumstances change so that a restriction begins to apply to you.

5.5 Restrictions that apply to your own business are your responsibility. Your obligations may be wider than Paysell's list — for example, your own license may prohibit markets that Paysell does not restrict.

6. How Paysell applies the list#

6.1 Restrictions are currently applied by manual review at shop approval, at verification, and when a concern arises. Paysell does not today operate automated geo-blocking of buyers or automated screening of merchants against sanctions lists; see the honest control table in the AML/CTF and Sanctions Policy. Merchants must not treat the absence of a block as confirmation that a transaction is permitted.

6.2 Paysell is building automated screening and address analytics. This document will be updated when they are in production.

6.3 Where a restriction is found to apply after a shop has been approved, Paysell will suspend the shop, hold the balance, and decide how to deal with the funds in accordance with applicable law and any direction from a competent authority. Funds connected to a sanctioned person may have to be frozen and reported rather than returned.

7. Requests for review#

7.1 If you believe a restriction has been applied to you in error — for example, a mismatch of name or an out-of-date address — write to [[Compliance email]] with an explanation and supporting documents.

7.2 Paysell will review, but is under no obligation to lift a restriction, and may be legally prohibited from explaining a decision or from unfreezing funds without authorization from the relevant authority.

7.3 Where funds are frozen for sanctions reasons, only the competent authority can authorize their release. Paysell cannot do so on its own initiative.

8. Changes to this document#

8.1 Paysell may add or remove jurisdictions at any time, with immediate effect where a sanctions or legal development requires it.

8.2 The current version, with its version number and effective date, is published at https://paysell.me/legal. Merchants materially affected by a change will be notified by e-mail or in the cabinet where that is lawful and practicable.

8.3 A change to this list may end Paysell's ability to serve an existing merchant. In that case Paysell will, where lawful, allow the merchant a reasonable period to withdraw its balance before closing the account.

Contact#

[[Company legal name]], [[Registered address]], [[Jurisdiction]]

• Sanctions and restriction questions, and review requests: [[Compliance email]]
• Legal notices and authority requests: [[Legal email]]
• General support: [[Support email]] or a ticket in the merchant cabinet