Risk appetite

Appetite And Restrictions On Nationalities And Residencies

Frontnode has a clearly defined appetite for which countries and
nationalities it wishes to serve. As part of this we are obligated to uphold current sanctions regimes subject to the country it operates from; Estonia. As such, Frontnode market
appetite is restricted to the European Economic Area (EEA https://trade.ec.europa.eu/access-to-markets/en/content/european-economic-area-eea-agreement).

If any EEA country is put on any of the below sanctions and Risk-lists, the listing will prevail, and our appetite will be adjusted accordingly until the country is de-listed.

Exceptions: We are able to serve individuals who are nationals and residents of countries identified as “low risk” and free of sanctions. However, this is only on a case-by-case basis and is dependent on us approving the Enhanced Due Diligence needed to accept and transact such clients.

For a full overview of relevant sanctions lists and countries, please see the following lists and their reasoning:

– EU Sanctions

Reasoning: https://www.eeas.europa.eu/eeas/european-union-sanctions_en

Map: https://www.sanctionsmap.eu/#/main

– OFAC sanctions

List: https://ofac.treasury.gov/sanctions-programs-and-country-information

– UN sanctioned countries and people

Active UN sanctions: https://www.un.org/securitycouncil/sanctions/2653/materials

– FATF

High risk countries: https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html

“Black & Grey” list for AML/CTF: https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html