Last updated: 27 August 2026
1. Purpose and Scope
Frontnode applies a risk-based approach to the countries and jurisdictions in which it provides services. This disclaimer explains the geographic restrictions that may apply to customers, beneficial owners, counterparties, transactions, payment instruments, bank accounts, wallets and other persons or assets connected with Frontnode’s services.
The restrictions are intended to protect Frontnode, its customers, banking and payment partners and the financial system against money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, cybercrime and other financial-crime risks, including the heightened risks associated with virtual currencies and cross-border crypto-asset transactions.
This disclaimer forms part of Frontnode’s compliance framework and should be read together with its Terms and Conditions, AML and KYC requirements, sanctions controls and any product-specific restrictions.
2. Basis for Geographic Restrictions
Frontnode determines geographic risk by reference to applicable laws and sanctions, the European Union’s list of high-risk third countries, FATF public statements and recommendations, national risk assessments, regulatory guidance, reliable financial-crime intelligence, the requirements of correspondent banks and payment partners, and Frontnode’s own risk appetite.
A country may be restricted even if it is not formally designated by the European Union or FATF. This may occur where Frontnode identifies material concerns relating to:
- international sanctions, embargoes or asset-freezing measures
- strategic deficiencies in anti-money laundering or counter-terrorist financing controls
- terrorist financing or proliferation financing exposure
- state-sponsored cybercrime, ransomware, fraud or sanctions evasion
- corruption, organized crime, trafficking or illicit financial flows
- weak or unavailable beneficial ownership information
- limited regulatory cooperation or unreliable customer information
- restrictions or prohibitions affecting virtual currencies or virtual asset service providers
- material exposure to mixers, tumblers, privacy-enhancing services, darknet markets or unhosted wallets
- difficulty obtaining reliable source-of-funds or source-of-wealth evidence or
- the inability or unwillingness of Frontnode’s banking, card, liquidity or payment partners to support the relevant activity.
3. Prohibited and Unsupported Countries and Jurisdictions
Frontnode does not ordinarily establish or maintain customer relationships, open accounts, accept registrations, process transactions or provide services where the customer or relevant activity has a material connection to any of the following countries or jurisdictions:
- Abkhazia
- Afghanistan
- Algeria
- American Samoa
- Angola
- Anguilla
- Antigua and Barbuda
- Belarus
- Bolivia
- Bosnia and Herzegovina
- British Virgin Islands
- Burundi
- Cameroon
- Central African Republic
- People’s Republic of China (mainland China)
- Côte d’Ivoire
- Cuba
- Democratic People’s Republic of Korea (North Korea)
- Democratic Republic of the Congo
- Egypt
- Eswatini
- Fiji
- Guam
- Guatemala
- Guinea
- Guinea-Bissau
- Guyana
- Haiti
- Indonesia
- Iran
- Iraq
- Jordan
- Kenya
- Kuwait
- Kyrgyzstan
- Lao People’s Democratic Republic (Laos)
- Lebanon
- Libya
- Republic of Moldova
- Monaco
- Morocco
- Mozambique
- Myanmar
- Nagorno-Karabakh
- Namibia
- Nepal
- Nicaragua
- Niger
- Pakistan
- Palau
- Palestinian Authority
- Panama
- Papua New Guinea
- Russian Federation
- Samoa
- Saudi Arabia
- Seychelles
- Somalia
- Somaliland
- South Ossetia
- South Sudan
- Sudan
- Syrian Arab Republic
- Tajikistan
- Trinidad and Tobago
- Tunisia
- Türkiye
- Turkmenistan
- Ukraine
- United Kingdom
- United States Virgin Islands
- Uzbekistan
- Vanuatu
- Venezuela
- Vietnam
- Yemen
- Zimbabwe
- Crimea, Sevastopol and the non-government-controlled areas of the Donetsk, Luhansk, Kherson and Zaporizhzhia regions of Ukraine, and any other territory subject to comprehensive applicable sanctions or equivalent restrictions.
These restrictions apply regardless of whether the proposed transaction is denominated in fiat currency, a stablecoin, another virtual currency or any other crypto-asset. Frontnode may permit an activity only where it is lawful, within Frontnode’s risk appetite, supported by its relevant partners and expressly approved in writing by Frontnode’s Compliance function. No customer has a right to receive such an exception.
4. Other Restricted or High-Risk Countries and Jurisdictions
Frontnode also treats the following countries and jurisdictions as restricted or high risk. Frontnode may decline service entirely or require enhanced due diligence and prior Compliance approval before establishing or continuing a relationship or processing a transaction:
- Barbados
- Belize
- Brazil
- Burkina Faso
- Comoros
- Isle of Man
- Jamaica
- Mali
- Montenegro
- Nigeria
- Philippines
- Saint Kitts and Nevis
- Senegal
- Serbia
- South Africa
- United Republic of Tanzania
- Uganda
- United Arab Emirates.
Inclusion in this section does not mean that all persons or transactions connected with a listed jurisdiction are unlawful or suspicious. It means that the relationship presents elevated risk or reduced bankability and is therefore subject to Frontnode’s internal restrictions, enhanced review or partner limitations.
5. What Constitutes a Country Connection
A restriction may apply where a relevant country or jurisdiction is connected to any aspect of the customer relationship or transaction. Relevant connections may include:
- citizenship, nationality, residence, domicile or physical location
- place of incorporation, registration, management or principal business activity
- the residence, nationality or location of a beneficial owner, director, authorized representative, controller or counterparty
- a bank account, payment card, payment institution, virtual asset service provider, exchange, custodian or wallet provider
- the origin, destination, source or intended use of funds or crypto-assets
- an IP address, telephone number, device, identity document, address or other technical or documentary indicator
- a blockchain wallet, protocol, smart contract, exchange or intermediary linked to the jurisdiction or
- goods, services, vessels, entities, persons or economic activity located in or connected with the jurisdiction.
The use of a virtual private network, intermediary, nominee, third-party wallet, offshore entity or indirect payment route does not remove the underlying geographic connection. Customers must not conceal, disguise or misrepresent any such connection.
6. Sanctions and Designated Persons
Frontnode does not provide services to, for the benefit of, or on behalf of any person, entity, vessel, wallet address or other property interest that is subject to applicable sanctions, asset-freezing measures or prohibitions. This restriction applies even where the relevant country is not listed in this disclaimer.
Frontnode screens customers and transactions against applicable sanctions and other relevant watchlists. It may also use blockchain analytics and other risk indicators to identify direct or indirect exposure to designated persons, sanctioned services, stolen assets, ransomware, terrorist financing, proliferation financing, fraud, darknet markets, mixers or other illicit activity.
7. Enhanced Due Diligence
Where Frontnode considers a relationship or transaction to be capable of acceptance despite elevated geographic risk, it may request additional information and evidence, including:
- enhanced identity and beneficial ownership documentation
- source-of-funds and source-of-wealth evidence
- the purpose and expected nature of the relationship or transaction
- supporting contracts, invoices, tax records or bank statements
- information concerning counterparties, wallets and virtual asset service providers
- an explanation of the customer’s connection to the relevant jurisdiction
- any further information required by Frontnode or its banking, payment, card, liquidity or compliance partners.
Frontnode may apply transaction limits, enhanced monitoring, delayed execution, senior management approval or other proportionate controls. Submission of information does not guarantee onboarding, continued service or execution of a transaction.
8. Crypto-Asset and Wallet-Specific Restrictions
Crypto-assets may move rapidly across borders and may obscure the location or identity of participants. Frontnode therefore assesses both the customer’s declared country information and the full transaction and blockchain context.
Frontnode may refuse, suspend or investigate a crypto-asset transaction where funds originate from, are destined for, or have material exposure to a restricted jurisdiction, sanctioned address, non-compliant virtual asset service provider, mixer or tumbler, darknet market, ransomware actor, stolen asset cluster, fraudulent scheme, privacy-enhancing service or other high-risk source.
A transaction may be restricted even if it passes through one or more intermediate wallets or exchanges before reaching Frontnode. Stablecoins are subject to the same geographic, sanctions and financial-crime controls as other virtual currencies.
9. Frontnode’s Rights and Customer Obligations
To the extent permitted or required by applicable law, Frontnode may:
- reject an application or transaction
- decline to accept a deposit or execute a withdrawal or transfer
- place an account or transaction under review
- request further information or documentary evidence
- restrict, suspend or terminate access to services
- return funds or crypto-assets where operationally and legally possible
- freeze, block or retain assets where required by law or a competent authority
- report suspicious activity or sanctions concerns to the appropriate authorities
- take any other action required by law, regulation, court order, regulatory direction or the requirements of a relevant financial or payment partner.
Customers must provide complete, accurate and current information, promptly notify Frontnode of any change in their country connections, and ensure that they do not use Frontnode’s services for or on behalf of a prohibited or undisclosed person or jurisdiction.
10. No Guarantee of Service
The country lists in this disclaimer are minimum public restrictions and are not exhaustive. A country’s absence from the lists does not mean that Frontnode is able or obliged to provide services there. Availability may depend on the customer type, product, currency, crypto-asset, transaction route, counterparty, licensing perimeter and the requirements of Frontnode’s partners.
Frontnode may decline or restrict a relationship or transaction based on its individual risk assessment without publicly disclosing confidential risk indicators, monitoring methods, partner requirements or information that could prejudice financial-crime controls.
11. Changes to Country Status
Country risk classifications, sanctions regimes, FATF statements, European Union listings and banking or payment partner requirements change over time. Frontnode may add, remove or reclassify a country or jurisdiction, and may apply a change immediately where required for legal, regulatory, sanctions, security or financial-crime reasons.
Customers should review the current version of this disclaimer before initiating a transaction. A transaction that was previously permitted may later be delayed, rejected or made subject to additional checks if the relevant risk, legal or partner position changes.
12. Legal Disclaimer
This document describes Frontnode’s general geographic risk policy. It does not constitute legal advice, a representation that services are available in any jurisdiction, or a complete statement of all applicable sanctions and financial-crime laws. Applicable law and binding regulatory or sanctions requirements prevail over this disclaimer.
Where a conflict exists between this disclaimer, Frontnode’s Terms and Conditions, a product-specific restriction or applicable law, the stricter requirement may be applied to the extent permitted by law.